Finding Text
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN:
84.007), Federal Work-Study Program (ALN: 84.033), Federal
Pell Grant Program (ALN: 84.063), Federal Direct Student
Loans (ALN: 84.268)
Criteria or Specific Requirement
(Including Statutory, Regulatory
or Other Citation):
E. Eligibility – Calculation of Benefits – Awards must be
coordinated among the various programs and with other
federal and nonfederal aid (need and non-need based aid) to
ensure that total aid is not awarded in excess of the student’s
financial need or cost of attendance (“COA”) (34 CFR 668.42,
FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR
685.301). For Title IV programs, the COA is generally the sum
of the following: tuition and fees; an allowance for books,
supplies, transportation, and miscellaneous personal
expenses; an allowance for room and board; when applicable,
allowances for costs for dependent care; costs associated
with study abroad and cooperative education; costs related
to disabilities; and fees charged for student loans.
Condition: For certain students identified through our testing, the
University did not properly calculate the student’s COA.
Cause: Administrative oversight and lack of sufficient internal
controls with respect to Title IV aid award eligibility.
Effect or Potential Effect: The University is not in compliance with aid awarding criteria
under the eligibility requirements. Failure to properly
determine students’ COAs and calculate eligible award
amounts could result in improper disbursements of Title IV
funds.
Questioned Costs: None.
Context: For 16 of 25 students selected for testing, the University
either did not properly calculate the student’s COA or was
unable to support the components of the student’s COA that
was used for awarding and disbursing Title IV aid. For all
students noted with COA issues, we determined that there
were no overawards of federal and nonfederal aid.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhance its policies,
procedures and internal controls to ensure that Title IV aid is
properly calculated, awarded and disbursed, consistent with
federal regulations.
Views of Responsible Officials
and Planned Corrective Actions:
For the 2023-2024 academic year Cost of Attendance Budgets
were reviewed and tested to correct any miscalculations and
omissions. Pell Budgets were updated to correctly
differentiate program tuition and fees. Testing for 2024-2025
academic year has been updated and reviewed to accurately
calculate Cost of Attendance Budgets. In some of the findings
it was later found that due to changes made in the student’s
record, the record should have run through the dynamic
redetermination process to update the budget. The staff has
been retrained in this process.
The process for summer periods of enrollment has been
reviewed and revised to flag students who initially applied
and or registered for summer classes and subsequently did
not register or dropped the classes during the add/drop
period and the summer period of enrollment remained,
thereby calculating a Cost of Attendance for summer.