Finding Text
FINDING #2023-003 – SPECIAL TESTS AND PROVISIONS: VERIFICATIONS
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance
Criteria or Specific Requirement: An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned.
Condition / Context: During our review of student verifications, we noted one student who was flagged for verification based on their Institutional Student Information Record (ISIR) #2, however, the student was never informed by the institution and never completed the process, but was awarded financial aid.
Questioned Costs: None.
Cause: Turnover in the Student Financial Aid office resulted in the system not updating ISIRs for a period of time. The problem has been fixed since.
Effect: Potential for overpayment for students flagged and not verified.
Repeat Finding: No.
Recommendation: We recommend that all process in place are written down so that in the case of turnover, process can continue to operate effectively.
Corrective Action Plan: Two staff members were assigned the responsibility and access to EDExpress, which allows the college to send and receive files (including ISIRs) between college and federal databases. Both employees were placed on immediate and unanticipated leave in March 2023, leaving interim staff without the access or authority to perform these functions. It took some time to update the school’s online access and we were instructed to start using a different software, EDconnect, since EDExpress was becoming obsolete. Administration rights and training were then given to interim staff on uploading ISIRs into the FA system (SAM), and written procedures were developed. In the case cited here, the student was paid just as the staffing and access issues occurred. Updated records were not downloaded until after access to EDconnect was implemented and staff received guidance on the correct procedure. Initially, the student’s file did not require verification prior to payment, but changes made to their FAFSA generated ISIR #2 which resulted in a new request for verification. This update was received late due to the access and software issue.
Since that time, we have developed written procedures on this process and trained additional staff. We have also created a new awarding and disbursement process and timeline, including required reconciliation of COD authorizations versus student awards and disbursements. This ensures students are properly awarded and disbursed, and that records between the two systems match. Uploads and downloads are now performed multiple times per week to ensure records are frequently updated.
In addition, the Financial Aid Office transition from the SAM to the Colleague Financial System will automate these functions to run daily, eliminating the need for manual uploads and downloads of data between the systems. Staff absences will no longer impact the timely updating of records.