Finding 404732 (2023-011)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2024-06-29
Audit: 311103
Organization: College Unbound (RI)

AI Summary

  • Core Issue: The College did not retain proof of high school diplomas for 2 out of 40 students, impacting their eligibility for federal aid.
  • Impacted Requirements: Compliance with 34 CFR 668.32, which mandates documentation of educational qualifications before disbursement.
  • Recommended Follow-up: The College should establish stronger internal controls to verify student eligibility for federal aid prior to disbursement.

Finding Text

Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 2 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs $29,187 Identification as a Repeat Finding, if applicable See finding 2022-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Corrective Action Plan: College Unbound has implemented a process to review eligibility for all new students. The Financial Aid Office works closely with Admissions/Recruiting to ensure proper documentation of all new students before the first disbursement. Timeline for Implementation of Corrective Action Plan: Ongoing. Started 8/22/24, fully implemented by the end of FY24. Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO

Categories

Questioned Costs Student Financial Aid Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 404720 2023-002
    Significant Deficiency Repeat
  • 404721 2023-003
    Significant Deficiency
  • 404722 2023-004
    Material Weakness Repeat
  • 404723 2023-004
    Material Weakness Repeat
  • 404724 2023-005
    Significant Deficiency
  • 404725 2023-006
    Material Weakness Repeat
  • 404726 2023-006
    Material Weakness Repeat
  • 404727 2023-007
    Significant Deficiency Repeat
  • 404728 2023-007
    Significant Deficiency Repeat
  • 404729 2023-008
    Material Weakness Repeat
  • 404730 2023-009
    Significant Deficiency
  • 404731 2023-010
    Significant Deficiency
  • 404733 2023-011
    Significant Deficiency Repeat
  • 404734 2023-012
    Significant Deficiency
  • 981162 2023-002
    Significant Deficiency Repeat
  • 981163 2023-003
    Significant Deficiency
  • 981164 2023-004
    Material Weakness Repeat
  • 981165 2023-004
    Material Weakness Repeat
  • 981166 2023-005
    Significant Deficiency
  • 981167 2023-006
    Material Weakness Repeat
  • 981168 2023-006
    Material Weakness Repeat
  • 981169 2023-007
    Significant Deficiency Repeat
  • 981170 2023-007
    Significant Deficiency Repeat
  • 981171 2023-008
    Material Weakness Repeat
  • 981172 2023-009
    Significant Deficiency
  • 981173 2023-010
    Significant Deficiency
  • 981174 2023-011
    Significant Deficiency Repeat
  • 981175 2023-011
    Significant Deficiency Repeat
  • 981176 2023-012
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.23M
84.063 Federal Pell Grant Program $1.04M
21.027 Coronavirus State and Local Fiscal Recovery Funds $809,807
84.116 Fund for the Improvement of Postsecondary Education $543,306
84.425 Education Stabilization Fund $324,547
84.007 Federal Supplemental Educational Opportunity Grants $12,170
84.033 Federal Work-Study Program $9,982