Finding Text
2024-004 U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Control
Criteria: Awards must be coordinated among the various programs and with other federal and
nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess
of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR
673.5 and 673.6; Direct Loan, 34 CFR 685.301). Financial need is defined as the student’s COA
minus the student’s EFC (as computed by the central processor and included on the student’s
SAR/ISIR).
Condition: During our testing of compliance for eligibility, we noted students who worked as
resident advisors for the University, did not have their Title IV aid adjusted for amounts they
received via direct payments to cover the cost of their housing.
Cause: The University compensated the students for the cost of their housing outside the
normal processing and packaging of Title IV aid. As a result, the student’s estimated financial
assistance (EFA) was understated allowing the student to be awarded additional aid they were
not eligible to receive.
Effect: Students who worked as Resident Advisors for the University during the current year,
were over awarded direct loans.
Questioned Costs: $26,572.
Context/Sampling: Sampling was not used. Students tested were specifically identified as those
who worked as resident advisors for the University.
Repeat Finding from Prior Year(s): No.
Recommendation: The University should review their current policies and procedures for
awarding Title IV aid to students who also receive subsidies from the University towards their
cost of attendance.Views of Responsible Officials: Management agrees with the finding.