Finding Text
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans.
E. Eligibility – Federal Pell Grant (Assistance Listing 84.063) – Each year, based on the maximum Pell Grant established by Congress, the ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (“EFC”) and COA. The Disbursement Schedules are used to determine annual awards for full time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student’s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times.
E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20).
Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Additionally, for certain students, the University improperly calculated the student’s Pell award. Furthermore, for certain students, the University awarded and disbursed FSEOG funds in excess of the annual maximum. Finally, the University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds.
Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility.
Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs, calculate eligible award amounts, and properly award aid in-line with the required guidelines could result in improper disbursements of Title IV funds.
Questioned Costs: Below reporting threshold.
Context: We noted the following exceptions: For 4 of 25 students selected for testing, the University did not properly calculate the student’s COA. For 1 of 25 students selected for testing, the University did not properly calculate the student’s Pell award.
For 1 of 25 students selected for testing, the University disbursed FSEOG funds in excess of the annual maximum grant allowed. 11 students disbursed FSEOG funds during the year were improperly given priority over Federal Pell Grant recipients.
Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-001 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend the University enhance its policies, procedures, and internal controls to ensure that Title IV aid is properly calculated, awarded, and disbursed, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and
disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly.
For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs.