Finding 44742 (2022-004)

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Requirement
E
Questioned Costs
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Year
2022
Accepted
2023-03-29
Audit: 39697
Auditor: Galindez LLC

AI Summary

  • Core Issue: One student received Title IV funds despite being ineligible due to a classification error by the Registrar.
  • Impacted Requirements: Compliance with 34 CFR Section 668.32(a)(1)(i) regarding student eligibility for federal financial assistance.
  • Recommended Follow-up: Enhance processes for reviewing student eligibility and improve controls over enrollment to prevent future errors.

Finding Text

Finding No. 2022-004 ? Compliance Requirements ? Eligibility Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.32(a)(1)(i) states that for a student to be eligible for student financial assistance programs, he or she must be a regular student enrolled or accepted for enrollment in an eligible program unless meeting an exception. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected all nine (9) students who withdrew, dropped out or failed to attend the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 11% of the sample selected, in which the University disbursed Title IV funds (Direct Loan) to a non-eligible student, as follows: ?See Schedule of Findings and Questioned Costs for chart/table Context Of the nineteen (19) cases of students who withdrew, dropped out, or failed to attend the University, we selected all nine (9) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (Direct Loans) with the required criteria. Of the nine (9) students selected for testing, only six (6) had received Direct Loans. The composition of the audit samples for the Direct Loan program and the population from which the samples were drawn were as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Cause The student was incorrectly classified as enrolled by the Registrar Department due to human error. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties on the University. In addition, it could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost As of the date the financial statements were available to be issued, questioned costs were not determined, since the amount of $14,423 had been paid by the University. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to improve its processes over the review of student?s eligibility to ensure that only eligible students receive financial aid under federal financial assistance programs. Furthermore, controls over student enrollment should be enhanced to ensure that only qualified students are registered as enrolled in the University. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.

Corrective Action Plan

The finding was due to a human error. The Registrar?s Office failed to notify the Finance Division and Financial Aid Division of the student enrollment cancellation. These kinds of human errors will be prevented with the following procedure established by the university: Beginning with academic year 2022-2023 (August-2022), the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs also attend to facilitate the discussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent to two consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letters to the faculty from the Office of the Dean of Academic Affairs to highlight the importance pf promptly referring any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status.

Categories

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $18.33M
84.063 Federal Pell Grant Program $432,691
93.732 Mental and Behavioral Health Education and Training Grants $327,617
93.060 Competitive Abstinence Education (cae) $270,254
84.938 Disaster Recovery Assistance for Education $184,834
84.031 Higher Education_institutional Aid $159,191
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $156,618
93.788 Opioid Str $151,151
93.866 Aging Research $116,292
93.855 Allergy, Immunology and Transplantation Research $82,898
84.425 Education Stabilization Fund $52,781
93.839 Blood Diseases and Resources Research $33,827
84.033 Federal Work-Study Program $30,975
93.424 Non-Aca/pphf?building Capacity of the Public Health System to Improve Population Health Through National Nonprofit Organizations $25,810
93.859 Biomedical Research and Research Training $22,780
84.007 Federal Supplemental Educational Opportunity Grants $12,451
93.763 Alzheimer?s Disease Initiative: Specialized Supportive Services Project (adi-Sss) Thru Prevention and Public Health Funds (pphf) $6,636
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $5,897
93.663 Extramural Research Restoration Program: Hurricanes Harvey, Maria, and Irma Non-Construction $2,496
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $1,493
93.498 Provider Relief Fund $1,236
93.279 Drug Abuse and Addiction Research Programs $600