Finding 519453 (2024-002)

Significant Deficiency
Requirement
E
Questioned Costs
$1
Year
2024
Accepted
2025-01-16

AI Summary

  • Core Issue: The College disbursed funds to four ineligible students due to ineffective internal controls over compliance.
  • Impacted Requirements: The College failed to meet the requirement set by 34 CFR 668.16(f) to verify discrepancies in student financial aid applications.
  • Recommended Follow-Up: The College should enhance internal control procedures to ensure student eligibility before disbursing funds.

Finding Text

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs. Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. Questioned costs: $19,435 Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435. Repeat finding: No Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.

Corrective Action Plan

2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. View of the responsible official: MACC does not agree with this finding. MACC has many measures in place to ensure funds are disbursed to eligible students, including verifying identity when enrolling degree seeking students in classes each semester and reviewing high school completion status with a high school transcript, as well as reviewing ISIRs, and other documentation to determine eligibility for federal student aid. While preparing disbursements for fall 2024, the Financial Aid Office identified some odd entries on some ISIRs, which prompted us to review various patterns in admissions documents. MACC believes the students in question may be cases of stolen identities. However, this is only suspicion at this time because when the students in question enrolled in the summer 2024 semester they provided identification, submitted high school transcripts from valid high schools, completed FAFSAs which resulted with valid ISIRs (in one case the student submitted Verification (V4) documentation), submitted loan data sheets and completed entrance counseling via Zoom. The students in question were referred to the Office of Inspector General at the U. S. Department of Education on 10/15/2024; no follow-up has been received from OIG as of 01/15/2025. MACC has also discussed this case with Kathy Feith, Region 7 Branch Chief, of the U. S. Department of Education, Federal Student Aid. During an interview with an auditor from CLA, MACC disclosed the situation described above to the auditor when questioned about any potential fraud cases. MACC firmly believes all internal control policies were followed to ensure funds were disbursed to eligible students. At the time of disbursement, there was no indication these students were not eligible. As noted above, the OIG has not determined that these are in fact ineligible students; therefore, MACC does not believe it should return funds based on suspicion of ineligibility. As a result of these findings, MACC has added new steps to provide an additional layer of protection, including verifying images of state drivers licenses or other forms of identity, and development of guidelines for staff to follow if they have any suspicion of fraud. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.

Categories

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Eligibility Significant Deficiency

Other Findings in this Audit

  • 519451 2024-001
    Significant Deficiency Repeat
  • 519452 2024-001
    Significant Deficiency Repeat
  • 519454 2024-002
    Significant Deficiency
  • 519455 2024-002
    Significant Deficiency
  • 519456 2024-002
    Significant Deficiency
  • 519457 2024-003
    Material Weakness Repeat
  • 519458 2024-003
    Material Weakness Repeat
  • 519459 2024-003
    Material Weakness Repeat
  • 519460 2024-003
    Material Weakness Repeat
  • 1095893 2024-001
    Significant Deficiency Repeat
  • 1095894 2024-001
    Significant Deficiency Repeat
  • 1095895 2024-002
    Significant Deficiency
  • 1095896 2024-002
    Significant Deficiency
  • 1095897 2024-002
    Significant Deficiency
  • 1095898 2024-002
    Significant Deficiency
  • 1095899 2024-003
    Material Weakness Repeat
  • 1095900 2024-003
    Material Weakness Repeat
  • 1095901 2024-003
    Material Weakness Repeat
  • 1095902 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $6.50M
84.268 Federal Direct Student Loans $3.27M
84.002 Adult Education - Basic Grants to States $468,377
21.027 Coronavirus State and Local Fiscal Recovery Funds $346,316
84.048 Career and Technical Education -- Basic Grants to States $308,881
11.307 Economic Adjustment Assistance $154,186
84.033 Federal Work-Study Program $150,459
84.007 Federal Supplemental Educational Opportunity Grants $68,608
17.268 H-1b Job Training Grants $57,701
47.076 Stem Education (formerly Education and Human Resources) $6,768
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $336