Finding 539078 (2024-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 349777

AI Summary

  • Core Issue: Two out of three sampled students worked during class time, violating federal regulations.
  • Impacted Requirements: Institutions must ensure work-study students do not work during scheduled class times, as per 34 CFR 675.19(a) and the Federal Student Aid Handbook.
  • Recommended Follow-Up: Update and reinforce policies for monitoring student work schedules to prevent conflicts with class times.

Finding Text

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Federal Work-Study (“FWS”) Assistance Listing #: 84.033 Award year: 2024-003 Criteria According to 34 CFR 675.19(a): The institution must establish and maintain program and fiscal records that include a certification by the student's supervisor, an official of the institution, or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for the students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. The 2023-2024 Federal Student Aid Handbook (Vol. 6, Pg. 33) states: In general, students are not permitted to work in Federal Work-Study positions during scheduled class times. Exceptions are permitted if the individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work- study experience. Any such exemptions must be documented. Condition Federal regulations require an institution to monitor and ensure that a work-study student is not working during his/her designated class time. Out of a sample of 3 students, we noted 2 students who worked during class time. Cause The College did not have adequate procedures in place to ensure that students did not work during class time. Effect Two students reported work-study time sheets conflicted with their respective class schedules. As a result of this scheduling conflict, the students either did not attend class or were not present during the documented time period for which they were paid Federal Work-Study wages. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 3 students selected for testing, 2 students, or 66% of our sample, were determined to have worked during class time. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that the College review, and if necessary, update the policies and procedures to ensure all Federal Work-Study supervisors are monitoring students' work time to ensure that it does not conflict with their class schedules. These policies should also be revisited and reinforced with those in charge of monitoring the students' federal work-study time. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Corrective Action Plan

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033 Award year: 2024 Corrective Action Plan: The Director of Financial Aid will send an email to all work-study supervisors outlining what has occurred and reminding them of the consequences of allowing students to work during scheduled class time and approving such time. These consequences include reallocating the funding source for the time worked from work-study to the area’s/department's budget, issuing written warnings to both the student and the supervisor, appointing a new supervisor for the area/department, or revoking the department’s ability to hire work-study students. Going forward, all work-study supervisors will be required to attend an in-person or virtual meeting with the Federal Work-Study Coordinator for an in-depth orientation, rather than completing it online. This meeting will thoroughly cover the program’s guidelines, including how to read a student’s schedule. A second email will be sent to all work-study students from the Director of Financial Aid reminding them of their student obligations, the contract they signed as a student worker, and the requirement that they are not allowed to work during class time. Additionally, going forward, all work-study students will be required to attend an in-person or virtual meeting with the Federal Work-Study Coordinator to review the program's guidelines rather than completing it online. Furthermore, the Director of Financial Aid will coordinate with the Payroll Office to conduct an internal audit of approved 2024-2025 academic year work-study timesheets to ensure compliance with all Federal regulations regarding students working during class time. If any issues are identified during the audit, the appropriate action/s from above will be enforced. Timeline for Implementation of Corrective Action Plan: The emails and in-person/virtual orientations will be implemented by April 2025. The internal audit of approved work-study timesheets will be completed by June 30, 2025. Contact Person Despina Lambropoulos, Director of Financial Aid

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 539074 2024-001
    Significant Deficiency
  • 539075 2024-001
    Significant Deficiency
  • 539076 2024-001
    Significant Deficiency
  • 539077 2024-002
    Significant Deficiency
  • 1115516 2024-001
    Significant Deficiency
  • 1115517 2024-001
    Significant Deficiency
  • 1115518 2024-001
    Significant Deficiency
  • 1115519 2024-002
    Significant Deficiency
  • 1115520 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $7.79M
84.268 Federal Direct Student Loans $1.86M
84.042 Trio Student Support Services $449,147
17.258 Wioa Adult Program $422,118
84.048 Career and Technical Education -- Basic Grants to States $302,966
84.007 Federal Supplemental Educational Opportunity Grants $238,513
84.910 Gallaudet University $232,777
21.027 Coronavirus State and Local Fiscal Recovery Funds $155,654
84.027 Special Education Grants to States $119,380
84.181 Special Education-Grants for Infants and Families $105,000
17.207 Employment Service/wagner-Peyser Funded Activities $63,335
17.270 Reentry Employment Opportunities $56,365
17.259 Wioa Youth Activities $53,053
17.245 Trade Adjustment Assistance $49,540
17.225 Unemployment Insurance $48,980
84.033 Federal Work-Study Program $44,629
84.425 Education Stabilization Fund $41,007
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $18,357
17.278 Wioa Dislocated Worker Formula Grants $16,752
17.801 Jobs for Veterans State Grants $15,623
84.002 Adult Education - Basic Grants to States $11,301