Finding No.: 2023-005
Recommendation
The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner.
Response
The College acknowledges the audit finding regarding verification errors, including the incorrect application of verification tracking groups, missing documentation, discrepancies between verification worksheets and ISIRs, and failure to make required corrections. In response, the Financial Aid Office (FAO) is committed to strengthening its verification procedures to ensure full compliance with federal regulations and to protect the integrity of Title IV funds. To this end, the College will implement the following corrective actions:
1. Policy and Procedure Enhancement
a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for the verification process, revise and update all existing verification worksheet forms. This SOP will include:
• Clear guidelines for identifying and applying the correct verification tracking groups (e.g., V1, V4, V5).
• Procedures for resolving discrepancies between verification worksheets and ISIRs prior to award disbursement.
• Steps for submitting timely and accurate ISIR corrections, as required.
• A documentation checklist to ensure all required verification forms and statements of educational purpose are collected and properly stored.
2. Policy and Procedure Enhancement
a. To ensure consistent understanding and application of federal verification rules, FAO staff across all campuses will:
• Complete mandatory annual training sessions on verification policies, ISIR review, and regularly read updates on the Federal Student Aid (FSA) Knowledge Center.
• Participate in internal refresher workshops focused on hands-on case processing and error prevention.
• Complete relevant modules from the Federal Student Aid (FSA) training site, including those on verification tracking groups and identity verification requirements.
3. Verification Quality Control Protocol
a. The FAO will implement a structured quality control protocol for verification, including:
• A two-person verification review system in which one staff member processes the file and another independently reviews it for accuracy and completeness.
• Use of a standardized review checklist to ensure all required documents match the ISIR and that any discrepancies are properly resolved and documented.
• A log of all verification actions, including corrections submitted to FAFSA Processing System (FPS) and updates made in the student’s file, to support audit readiness.
4. Oversight and Accountability
a. The Director of the Financial Aid Office (FAO) will be responsible for overseeing verification compliance and ensuring corrective actions are implemented effectively. This includes:
• Monitoring the accuracy of verification tracking group assignments and documentation across all campuses.
• Tracking the completion of required training for all FAO staff.
• Conducting quarterly file audits to verify ongoing compliance with federal verification standards.
• Reporting findings and corrective actions quarterly to the VPEMSS).
Contact: VPEMSS
Completion Date - September 30, 2025