Finding Text
Finding number: 2022-003
Federal agency: U.S. Department of Education
Programs: Student Financial Assistance Cluster
Assistance Listing #: 84.063, 84.007, and 84.268
Award year: 2022
Compliance Requirement: Eligibility
Criteria
According to 34 CFR 668.32:
A student is eligible to receive Title IV, HEA program assistance if the student either meets
all of the requirements in paragraphs (a) through (m) of this section or meets the
requirement in paragraph (n) of this section as follows:
(e) (1) Has a high school diploma or its recognized equivalent
Condition
The Federal Government requires that evidence of a high school diploma, its recognized
equivalent, or an alternative educational requirement be provided by the student prior to their first
disbursement. During our testing, we noted the College failed to retain a high school diploma or
recognized equivalent for 4 students, out of a sample of 40. As a result, the College was unable to
provide the necessary documentation to support the students’ eligibility. Our sample was not, and
was not intended to be, statistically valid.
Cause
The College failed to have the proper internal controls in place to validate that students are
eligible to receive Title IV prior to their first disbursement.
Effect
The students were awarded and disbursed federal student aid that they may not be eligible to
receive.
Questioned Costs
Not applicable
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should implement internal control procedures to ensure all students are eligible to
receive federal student aid before their first disbursement.
View of Responsible Officials
The College agrees with the finding.