Finding Text
2024-001 Minimum Award Amount
Compliance Requirement Allowable Costs / Cost Principles
Finding Type Significant Deficiency in Internal Controls and Noncompliance
Federal Agency US Department of Education
ALN 84.042A
Federal Program TRIO Cluster Program
Criteria
Section 402D(e) of the Higher Education Act of 1965, as amended, postsecondary institutions receiving funds under the Student Support Services (SSS) Program—part of the TRIO Cluster—are required to provide grant aid to eligible students in an amount that is at least equal to the minimum Federal Pell Grant for the applicable award year, unless the student is receiving other grant aid that meets or exceeds that amount. This requirement is further emphasized in U.S. Department of Education (USDE) grant award notifications and program guidance. For the 2023–2024 academic year, the minimum Pell Grant award was $692, effective beginning March 15, 2022, as established by the Consolidated Appropriations Act, 2022.
Condition
The institution awarded $650 in grant aid to eligible students under the TRIO Cluster Program. However, federal regulations require that the minimum amount of grant aid provided under TRIO programs, must be at least equal to the minimum Pell Grant award in effect at the time. For the award year, that minimum was $692, as established by the Consolidated Appropriations Act, 2022. Therefore, the grant aid amount awarded fell short of the federally required minimum.
Cause
The TRIO program Directors relied on the January 2022 version of the Pell Grant Payment and Disbursement Schedules, which listed the minimum Pell award as $650. This version was superseded in March 2022 by a revised schedule that increased the minimum award to $692, due to updated federal appropriations.
Effect
Distributing less than the minimum Pell Grant amount violates federal regulations, specifically those outlined in 34 CFR Part 690, and can lead to significant consequences. Financially, students may receive less aid than they are entitled to, resulting in underpayment and potential reimbursement requirements for institutions. This non-compliance can trigger findings during audits or reviews by the USDE, possibly leading to penalties such as fines or restrictions on federal financial aid program participation.
Questioned Costs
None
Recommendation
Administratively, institutions may need to implement corrective actions, including updating procedures and staff training, and report the violation and corrective measures to the Department of Education. For students, receiving less aid can cause financial hardship, affecting their ability to continue their education and eroding trust and satisfaction among students and their families. Addressing these implications promptly is crucial for maintaining compliance and supporting students' educational goals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)