Finding Text
Finding 2022-001 Errors in the Verification and Updating of Student Aid Applications Federal Department: U.S. Department of Education Assistance Listing Numbers: 84.038, 84.033, 84.007, 84.063, 84.268, 84.379 Cluster Name: Student Financial Assistance Cluster Programs: Federal Perkins Loan Program, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans, Teacher Education Assistance for College and Higher Education Grants Award Numbers: P033A211250, P007A211250, P268K211372, P268K221372, P063P201372, P063P211372, P379T221372 Questioned Cost: None Program Expenditures: $26,737,116 Olivet Nazarene University?s (University) student verification procedures did not function as designed. We tested a sample of 60 students receiving student financial assistance and noted 8 of those students were selected by the U.S. Department of Education (ED) for verification. An additional 17 students (selected for verification by ED) were added to the testing sample, increasing the verification testing population to 25 students. For 1 of the 25 student verifications tested, the University did not accurately update verification data with the Central Processor. The sample was not intended to be, and was not, a statistically valid sample. We noted: ? For one student, the verification documents submitted by the student evidenced Education Credits of $798. The information sent to the Central Processor by the University reported Education Credits of $0, a difference of $798. This error resulted in the student not receiving $200 of Pell, for which the student was eligible. The Code of Federal Regulations (Code) (34 CFR 668.59(a)) requires for the subsidized student financial assistance programs, if an applicant?s FAFSA information changes as a result of verification, the applicant or the institution must submit to the Secretary any changes to a nondollar item or a single dollar item of $25 or more. The Code (34 CFR 668.59(b)) further requires the University to recalculate the applicant?s Federal Pell Grant on the basis of the corrected information and disburse additional funds based on the recalculation. The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that student verifications are properly performed. University officials indicated that it was missed by the verification specialist, and not a matter of process. The specialist simply missed the line on the tax document listing the education credits. This caused the student to receive $200 less Pell funding than the student was eligible for. Failure to accurately verify student eligibility data increases the risk that students may be over or under awarded financial aid and may result in a loss of future Federal funding. (Finding Code No. 2022-001) Recommendation We recommend the University improve its procedures to ensure students that have been selected for verification are accurately verified in accordance with ED regulations. University Response The University agrees with the finding. The student should have received $200 in additional Pell Grant funds, so the school contacted the student and applied $200 in university funding to offset that loss. The verification specialist has been instructed about this important process.