Finding Text
2024-007
8515.01
Department Of Education
Student Financial Aid
84.063, 84.268
"P063P218567-2024
P268K228567-2024"
N/A
N/A
7/1/23 - 6/30/24
Significant Deficiency
Did not result in material questioned costs therefore will document as a SD.
Finding is neither systemic nor will it lead to 5% questioned cost.
N/A
"Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Per 34 CFR 690.62 states the Pell grant for an academic year is based
upon the payment and disbursement schedule published by the Secretary for each award year.
34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance."
The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, the University did not notify 3 students of required exit counseling. The University also incorrectly disbursed Pell funds for 4 students.
1845
E
During our eligibility testing of 60 students, we noted that the university did not document evidence of review for controls performed by their third party servicer. The University did not document review of award packaging, professional judgment determinations, COD reporting, or verification procedures. We also noted that 3 students were graduates or withdrawals but did not receive notifcation of required exit counseling. Additionally, out of 37 students receiving Pell, 3 were overawarded and 1 was underawarded. 1 student had an incorrect EFC used in their award packaging.
The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements.
No
We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Management agrees with this finding.
See 0100.25