Finding 2024-002
Program: Federal Work-Study Program
Assistance Listing No.: 84.033
Federal Agency: Department of Education
Award Year: FY 2023 - 2024
Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students
are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts
paid are appropriately earned.
University’s Response:
The University continues to emphasize and reinforce with its students and student supervisors that,
regardless of whether jobs are funded by the Federal Work Study program or by the institution, students
must not be working during scheduled class hours regardless of whether the class is cancelled or let out
early. The Student Employment Program holds annual training sessions for and provides updated
publications to these responsible individuals. As part of the University student employment application
process, students must submit their class schedule with their application. The University expects
supervisors to utilize the student class schedules provided and keep work schedules distinct. The University
also expects that supervisors continue to obtain students class schedules each semester and updates
students work schedules accordingly each semester to ensure students are not working during times they
are in class.
The University continues to use the internal audit process it instituted in February 2023. A sample of student
work records from the previous semester will be compared to students’ class schedules to ensure students
are not working during class hours. This review will be performed by Michael Peeler, Vice President for
Financial Affairs. Any violations of the school’s student employment policies identified in this audit will be
reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken.
Corrective Action Plan:
The University’s Student Employment Office continues to send monthly emails to student employee
supervisors and to the student staff, reminding them of the student employment guidelines they are
expected to abide by. This communication reminds them of their responsibility to adhere to student
employment guidelines and their responsibility to keep their supervisor informed of any changes they may
make to their class schedule that could require their work schedule to be adjusted. Since the hours of
overpayment appeared to be resulting from students failing to clock out and managers failing to catch
inaccurate hours of record (working for eight or more hours in a day, working overnight, etc.), further training
and instruction to pay closer attention to these discrepancies so they are corrected at the time of approving
timesheets has been provided to student employee supervisors as part of the monthly email
communication. Student employee supervisors will continue to be expected to hold a mandatory meeting
with their student staff at or before the start of each semester.The University’s internal audit process is also being expanded to be performed quarterly, twice each
semester. This process will continue to sample student work records at the midpoint and end of the fall
and spring semesters, where students’ class schedules are compared to hours worked to ensure students
are not working during class hours. Michael Peeler, Vice President for Financial Affairs, will perform this
review. Any violations of the school’s student employment policies identified in this audit will be reported
to Marc Sears, Vice President of Human Resources, for corrective action to be taken.
Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services;
Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human
Resources; Brad Calloway, Senior Vice President for Business Affairs
Anticipated Completion Date: March 31, 2025