Finding Text
2024 001 Special Tests and Provisions (Verification)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student’s output documents.
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
For two of the nineteen students selected for verification in fiscal year 2024, the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification for the V4 verification status.
There were a total of ninety-nine students in fiscal year 2024 selected for V4 or V5 verification and required to submit a Statement of Educational Purpose. The University performed an analysis to determine the total number of students impacted by this issue. There were a total of four students (including the two students mentioned in this finding) for which the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification.
Cause:
The University incorrectly coded high school completion documents as the Statement of Educational Purpose for these two students and therefore did not properly obtain a signed Statement of Educational Purpose to properly complete verification. The management review control over the verification process did not operate at a precise enough level to identify miscoding of the high school completion documents.
Effect:
The verification was not properly completed for these students.
Questioned Costs:
None, as the students were ultimately awarded and disbursed the correct amount of student financial aid.
Recommendation:
We recommend the University ensure that it follows its current policies and procedures to ensure that the proper documentation is requested and completed for the student as required for the verification status.
Views of Responsible Officials:
The University acknowledges that it incorrectly coded other documents as the Statement of Educational Purpose for the two students selected and therefore did not obtain a signed Statement of Educational Purpose to properly complete verification. The University has enhanced its report for required verification documentation to highlight those selected with V4 or V5 status to ensure all proper documentation is requested and provided by the students as required for the verification status. The review will be done on a monthly basis throughout the fiscal year.