Finding 577240 (2023-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2023-10-27
Audit: 1535
Organization: Art Academy of Cincinnati (OH)

AI Summary

  • Core Issue: The Vice President of recruitment received a $9,000 bonus linked to enrollment success, violating federal regulations prohibiting incentive payments for recruitment activities.
  • Impacted Requirements: This finding breaches CFR 668.14(22)(1), which restricts bonuses based on enrollment or financial aid success for those involved in student recruitment.
  • Recommended Follow-Up: The Academy should revise its bonus structure to implement blanket bonuses not tied to performance metrics related to recruitment or financial aid.

Finding Text

Federal Program: Federal Supplemental Educational Opportunity Grants (FSEOG) [AL #84.007], Federal Work-Study Program [AL #84.033], Federal Pell Grant Program [AL #84.063], and Federal Direct Student Loans [AL #84.268]. Criteria: Per CFR 668.14(22)(1) An institution will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the aware of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds. Condition: The Vice President of recruitment was paid a performance bonus of $9,000 based on completing a defense which included his recruitment activities for the year. Cause: The Academy gave all executive positions a bonus during the year but required them to complete a defense based on their current year accomplishments. Effect: The Academy paid a $9,000 bonus based on securing enrollments. Questioned Costs: $9,000 Context: This is not a systemic problem. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Academy review their bonus process and consider awarding blanket bonuses not based on performance. Views of Responsible Officials: For the executive bonuses, the Academy will award a blanket bonus based on a review from the executives’ team members and manager, which provides feedback on overall leadership and communication skills associated with the teams being managed by the Academy executives. The review will not include any data regarding attaining certain metric related to recruitment and attaining any financial aid goals.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 795 2023-001
    Significant Deficiency
  • 796 2023-002
    Significant Deficiency
  • 797 2023-001
    Significant Deficiency
  • 798 2023-001
    Significant Deficiency
  • 799 2023-001
    Significant Deficiency
  • 577237 2023-001
    Significant Deficiency
  • 577238 2023-002
    Significant Deficiency
  • 577239 2023-001
    Significant Deficiency
  • 577241 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.33M
84.063 Federal Pell Grant Program $704,513
84.007 Federal Supplemental Educational Opportunity Grants $25,250
84.033 Federal Work-Study Program $25,000
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $10,178