Finding Text
Federal Pell Grant Program, Assistance Listing Number 84.063
Federal Direct Student Loans, Assistance Listing Number 84.268
Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033
Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.
Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation.
Questioned costs – $2,000
Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid.
Effect – the University was not in compliance with its PPA during the year.
Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.
Identification as repeat finding, if applicable – N/A
Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.
Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.