Finding Text
Special Tests and Provision
Student Financial Assistance Cluster of Programs
84.033 Federal Work-Study Program
U.S. Department of Education
Criteria: 34 CFR 675.19(b)(1) An institution must follow the record retention and examination provisions in this part and in 34 CFR 668.24.
34 CFR 675.19(b)(2) The institution must also establish and maintain program and fiscal records that -
(i) Include a certification by the student's supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day;
(ii) Include a payroll voucher containing sufficient information to support all payroll disbursements;
(iii) Include a noncash contribution record to document any payment of the institution's share of the student's earnings in the form of services and equipment (see § 675.27(a)); and
(iv) Are reconciled at least monthly.
Condition: A sample of thirty-seven students was selected for student file and account testing. Of those tested, nine earned federal work study wages during the audit period. For two of these students, the College was able to provide approved timesheets and payroll vouchers but was unable to locate employment files including documentation substantiating existence, eligibility, and agreement of employment under the federal work study program.
Context: This was discovered during the audit testing of federal work study.
Effect: The College did not have documented employment files demonstrating existence, eligibility, and agreement of employment for federal work study students.
Cause: These appeared to be isolated incidents during a time where payroll management was moved to a new department at the College.
Recommendation: We recommend that the College update their internal documentation process to ensure all students hired have complete student employment files.
Views of responsible officials: This issue occurred as employee files and onboarding were managed by the Human Resources department, which had also been running payroll. The matter has since been resolved as the accounting department reassumed responsibility for running payroll and is serving as a cross check to ensure that all necessary documentation has been verified as collected by the Human Resources department at the time of onboarding. The responsibility of the Human Resources department remains to ensure that all employee onboarding files are available for review while accounting as the payroll processor shall confirm that student work study hours have been documented and approved by the appropriate supervisor.