Management Response to Section III-Federal Award Findings and Questioned Costs, Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.038, 84.063, 84.268 – Finding No. 2024-01
Compliance Requirement Finding: Eligibility
Students receiving federal aid are required to be U.S. citizens, Nationals, or provide evidence from the U.S. Citizenship and Immigration Services that he or she is a permanent resident or in the U.S. with the intention of becoming a citizen or permanent resident (eligible noncitizen). The financial aid counselor did not obtain proper documentation and approval to determine that the student was an eligible noncitizen. As such, the University disbursed federal aid to a student that was improperly documented as an eligible noncitizen. The federal aid was reversed and replaced with institutional funds.
Corrective Action Plan
In response to the finding on the FY2024 Single Audit, the University conducted an additional internal review on 25% of the student records that were not pulled in the audit sample where citizenship verification was required. This review included verification of having valid documentation in accordance with the U.S. Department of Education regulations and confirmation that the secondary verification was completed per existing operating protocol. The University found no additional instances and therefore believes this to be an isolated incident.
As a preventative measure and to mitigate potential recurrence, additional training has been conducted with the Student Financial Aid Staff to reemphasize and reinforce University policy and procedures concerning verification in accordance with the University’s Policy for Verification, in particular section 3(B), which states:
“All completed verification must have a secondary review by the Associate Vice President for Student Financial Services, Associate Director of Student Financial Services, or another financial aid counselor. Appropriate signatures must be noted on all verifications completed.”
Throughout the FY2025 year, the University will also provide randomized internal audits on a sampling of the student files containing citizenship verification to ensure the protocols are being followed as presented. This review will be conducted by the Associate Vice President for Student Financial Services for files where not part of the initial secondary review process or by the Vice President of Operations and Chief Financial Officer or the Assistant Vice President and Controller when the Associate Vice President for Student Financial Services is the secondary reviewer.
J.W. Kellam
james.kellam@converse.edu
Associate Vice President for Student Financial Services