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):
N. Special Test and Provisions – Verification - An institution
shall require an applicant selected for verification to submit
acceptable documentation that will verify or update the
following information used to determine the applicant's EFC:
adjusted gross income, U.S. income tax paid, aggregate
number of family members in the household, number of
family members in the household who are enrolled in as at
least half-time students in postsecondary educational
institutions if that number is greater than one and untaxed
income subject to U.S. income tax reporting requirements in
the base year which is included on the tax return form,
excluding information contained on schedules appended to
such forms. Untaxed income and benefits include: Social
Security benefits if the institution has reason to believe that
those benefits were received and were not reported or were
not correctly reported; child support if the institution has
reason to believe child support was received; U.S. income tax
deductions for a payment made to an individual retirement
account or Keough account; interest on tax-free bond; foreign
income excluded from U.S. income taxation if the institution
has reason to believe that foreign income was received; and
all other untaxed income subject to U.S. income tax reporting
requirements in the base year included on the tax return
form, excluding information contained on schedules
appended to such forms. (34 CFR section 668.56).
Condition: For certain students selected for verification, the information
required to be verified did not match the underlying
supporting documentation.
Cause: Administrative oversight and lack of sufficient internal
controls with respect to verification procedures.
Effect: Federal awards were not disbursed in accordance with federal
regulations, and the University was not in compliance with
verification compliance requirements.
Questioned Costs: Sampled questioned costs: $3,645; total questioned costs:
indeterminable.
Context: For 4 of 25 students selected for verification testing, the
University did not perform appropriate verification
procedures.
Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as
Finding 2022-003 in the prior year schedule of findings and
questioned costs.
Recommendation: We recommend the University enhance its policies,
procedures and internal controls to ensure that the
appropriate verification procedures are performed for all
students who are selected for verification unless excluded by
the federal regulations.
Views of Responsible Officials and
Planned Corrective Actions:
During the 2023 and 2024 fiscal years, the Financial Aid office
experienced several staffing changes, including the
termination of the Financial Aid Director. The newly hired
staff did not receive the proper training to perform their roles
effectively. This led to errors in verifying certain data when
performing verification. The previous Financial Aid Director
was terminated before the prior corrective action plan could
be completed. In March 2023, a consultant firm was engaged
to assist with the 2024 fiscal year.
The Financial Aid office will implement a Quality Assurance
two-step verification process. The financial aid advisor will
work with the student to gather necessary documents and
perform the original verification. The Associate Director of
Financial Aid will review these verifications and update them
in Colleague to be transmitted to COD for corrections if
needed.
The Financial Aid office will run a report to identify all
students selected for verification for 2023-2024 and review
them for accuracy. If any corrections are needed they will be
updated and awards will be adjusted as needed.