FAC Explorer

Finding 7214 (2023-001)

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Requirement
EHN
Questioned Costs
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Year
2023
Accepted
2024-01-03
Audit: 9367
Organization: Yale University (CT)
Auditor: Pricewaterhousecoopers LLP

AI Summary

  • Core Issue: The University lacks consistent policies and procedures for documenting compliance with student financial aid regulations.
  • Impacted Requirements: Key areas needing improvement include verification documentation, electronic consent, Title IV calculations, enrollment data communication, and satisfactory academic progress policies.
  • Recommended Follow-Up: Establish uniform policies, enhance training for financial aid staff, and ensure compliance documentation is maintained across all departments.

Finding Text

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV, HEA programs (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loan $85.37M
97.036 Covid-19 Disaster Grants -Public Assistance $15.82M
84.063 Federal Pell Grant Program $6.99M
98.RD Agency for International Development $4.11M
81.RD Department of Energy $2.60M
93.283 Centers for Disease Control and Prevention_investigations and Technical Assistance $2.18M
84.033 Federal Work-Study Program $1.70M
19.RD U.s Department of State $1.51M
93.914 Hiv Emergency Relief Project Grants $1.21M
12.910 Research and Technology Development $942,471
93.866 Aging Research $897,379
84.007 Federal Supplemental Educational Opportunity Grants $849,901
93.279 Drug Abuse and Addiction Research Programs $844,193
93.969 Pphf Geriatric Education Centers $838,800
47.070 Computer and Information Science and Engineering $783,106
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $710,025
93.395 Cancer Treatment Research $673,178
93.RD Department of Health and Human Services $661,531
93.855 Allergy and Infectious Diseases Research $655,701
12.800 Air Force Defense Research Sciences Program $652,244
93.354 Covid-19 Phep Crisis Response $643,118
47.041 Engineering Grants $639,663
93.242 Mental Health Research Grants $590,875
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $577,304
93.865 Child Health and Human Development Extramural Research $563,360
43.001 Science $514,638
93.732 Mental and Behavioral Health Education and Training Grants $507,842
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $493,308
66.509 Science to Achieve Results (star) Research Program $477,100
93.396 Cancer Biology Research $453,288
93.127 Emergency Medical Services for Children $450,479
98.001 Usaid Foreign Assistance for Programs Overseas $448,746
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $444,721
93.364 Nursing Student Loans $440,885
84.305 Social and Behavioral Context for Academic Learning $432,455
10.309 Specialty Crop Research Initiative $429,545
93.884 Grants for Primary Care Training and Enhancement $425,904
47.049 Mathematical and Physical Sciences $408,766
93.213 Research and Training in Complementary and Integrative Health $398,079
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $389,398
93.145 Hiv-Related Training and Technical Assistance $377,328
93.110 Maternal and Child Health Federal Consolidated Programs $370,016
93.172 Human Genome Research $357,440
93.867 Vision Research $315,377
93.837 Cardiovascular Diseases Research $301,128
12.431 Basic Scientific Research $292,918
93.185 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $291,068
93.838 Lung Diseases Research $287,390
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $280,593
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $276,206
93.143 Niehs Superfund Hazardous Substances_basic Research and Education $258,450
93.273 Alcohol Research Programs $256,294
93.121 Oral Diseases and Disorders Research $239,005
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $238,529
93.393 Cancer Cause and Prevention Research $235,935
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $235,917
12.420 Military Medical Research and Development $231,805
12.RD Department of Defense $229,781
12.300 Basic and Applied Scientific Research $223,466
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $216,192
93.262 Occupational Safety and Health Program $214,567
93.310 Trans-Nih Research Support $213,114
10.310 Agriculture and Food Research Initiative (afri) $208,844
84.015B National Resource Centers Program $207,187
20.RD Department of Transportation $204,743
81.049 Office of Science Financial Assistance Program $200,442
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $198,917
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $197,402
93.928 Special Projects of National Significance $196,306
93.361 Nursing Research $194,894
93.173 Research Related to Deafness and Communication Disorders $186,221
16.575 Department of Justice $184,540
93.226 Research on Healthcare Costs, Quality and Outcomes $178,324
93.788 Opioid Str $177,150
21.027 American Rescue Plan Act Funds $176,752
93.U10 Department of Health and Human Services $167,928
93.350 National Center for Advancing Translational Sciences $165,386
93.U09 Department of Health and Human Services $164,280
11.431 Climate and Atmospheric Research $163,615
47.050 Geosciences $160,843
93.U08 Department of Health and Human Services $154,405
84.425F Heerf II Institutional Grants $151,777
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation?s Health $149,927
66.RD Environmental Protection Agency $147,884
93.859 Biomedical Research and Research Training $144,085
98.U12 Agency for International Development $143,587
15.506 Water Desalination Research and Development $142,403
93.233 National Center on Sleep Disorders Research $136,219
43.RD National Aeronautics & Space Administration $134,083
47.RD National Science of Foundation $133,674
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $131,914
93.958 Block Grants for Community Mental Health Services $129,728
93.989 International Research and Research Training $124,570
93.940 Hiv Prevention Activities_health Department Based $122,259
93.113 Environmental Health $120,624
93.307 Minority Health and Health Disparities Research $118,547
47.083 Office of Integrative Activities $116,433
47.078 Polar Programs $113,513
93.839 Blood Diseases and Resources Research $107,476
93.U07 Department of Health and Human Services $104,000
93.394 Cancer Detection and Diagnosis Research $102,846
93.U06 Department of Health and Human Services $101,634
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $97,869
12.750 Uniformed Services University Medical Research Projects $92,677
47.079 Office of International Science and Engineering $92,242
45.312 National Leadership Grants $90,849
84.022A Fulbright-Hays Doctoral Dissertation Research Abroad (ddra) Fellowship Program $89,545
43.012 Space Technology $89,317
93.397 Cancer Centers Support Grants $86,610
84.423 Supporting Effective Educator Development Program $80,360
10.174 Acer Access Development Program $77,450
93.391 Nursing Research $76,399
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $75,862
98.U11 Agency for International Development $64,820
95.007 Research and Data Analysis $62,071
93.926 Healthy Start Initiative $59,378
16.026 Ovw Research and Evaluation Program $56,603
93.879 Medical Library Assistance $54,871
10.215 Sustainable Agriculture Research and Education $54,805
81.049 Office of Science Financial Assistance Program - Energy $54,120
84.022 Fulbright-Hays Doctoral Dissertation Research Abroad (ddra) Fellowship Program $53,510
10.001 Agricultural Research_basic and Applied Research $51,034
47.074 Biological Sciences $50,893
45.169 Promotion of the Humanities_office of Digital Humanities $48,500
93.297 Teenage Pregnancy Prevention Program $46,495
45.313 Laura Bush 21st Century Librarian Program $42,376
19.040 Public Diplomacy Programs $41,688
45.024 Promotion of the Arts_grants to Organizations and Individuals $40,000
19.025 U.s. Ambassadors Fund for Cultural Preservation $38,630
93.U05 Department of Health and Human Services $36,134
45.301 Museums for America $35,915
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $31,627
93.488 National Harm Reduction Technical Assistance and Syringe Services Program (ssp) Monitoring and Evaluation Funding Opportunity (b) $31,214
93.399 Cancer Control $29,286
84.015A National Resource Centers Program $28,334
93.321 Dietary Supplement Research Program $28,060
43.007 Space Operations $28,002
93.247 Advanced Nursing Education Grant Program $26,802
93.266 Health Systems Strengthening and Hiv/aids Prevention, Care and Treatment Under the President's Emergency Plan for Aids Relief $24,135
93.575 Child Care and Development Block Grant $23,498
10.RD Department of Agriculture $23,190
47.075 Social, Behavioral, and Economic Sciences $21,139
45.026 Promotion of the Arts_leadership Initiatives $20,000
93.070 Environmental Public Health and Emergency Response $19,268
93.959 Block Grants for Prevention and Treatment of Substance Abuse $18,987
93.U04 Department of Health and Human Services $18,000
93.313 Nih Office of Research on Women's Health $17,683
11.417 Sea Grant Support $16,527
10.164 Wholesale Farmers and Alternative Market Development $15,020
84.305A Social and Behavioral Context for Academic Learning $14,590
12.400 Military Construction, National Guard $14,550
10.707 Research Joint Venture and Cost Reimbursable Agreements $14,524
66.604 Environmental Justice Small Grant Program $13,791
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $13,523
10.652 Forestry Research $13,051
93.351 Research Infrastructure Programs $11,897
16.575 Crime Victim Assistance $10,089
15.657 Endangered Species Conservation Recovery Implementation Funds $9,266
93.U03 Department of Health and Human Services $8,892
66.516 P3 Award: National Student Design Competition for Sustainability $5,913
93.516 Public Health Training Centers Program $4,155
93.068 Chronic Diseases: Research, Control, and Prevention $4,000
93.136 Injury Prevention and Control Research and State and Community Based Programs $3,733
45.149 Promotion of the Humanities_division of Preservation and Access $3,529
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students $3,158
64.RD Department of Veterans' Affairs $2,830
10.250 Agricultural and Rural Economic Research, Cooperative Agreements and Collaborations $2,637
47.076 Education and Human Resources $2,141
93.117 Preventive Medicine and Public Health Residency Training Program, Integrative Medicine Program, and National Center for Integrative Primary Healthcare $1,784
93.398 Cancer Research Manpower $1,597
81.135 Advanced Research Projects Agency - Energy $1,132
93.U02 Department of Health and Human Services $1,067
43.008 Education $1,000
12.630 Basic, Applied, and Advanced Research in Science and Engineering $14
93.103 Food and Drug Administration_research $1
84.038 Federal Perkins Loan Program $0
81.087 Renewable Energy Research and Development $-1,363
93.U01 Department of Health and Human Services $-1,840