Finding Text
Finding 2023-009 – E. Eligibility – Cost of Attendance and Overaward of Title IV Funds
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN’s 84.007, 84.033, 84.063, 84.268, 84.379)
Criteria or Specific Requirement - Schools should establish average costs for different categories of students to calculate their award amounts and package their aid. When calculating cost of attendance, institutions may apply professional judgment to make adjustments to individual students' cost of attendance when special circumstances apply. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students (20 U.S.C. 1087ll, 20 U.S.C. 1087tt).
Condition – The University could not provide supporting documentation for its use of professional judgement for certain students and also miscalculated cost of attendance for certain students.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with cost of attendance for eligibility requirements.
Questioned Costs – Three students were awarded a total of $22,382 in excess of eligible Title IV funds.
Context – The context for this finding is as follows:
• For 2 of 40 students tested, the University did not retain documentation of its use of professional judgment.
• For 3 of 40 students tested, the University did not properly calculate cost of attendance.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-003.
Recommendation – We recommend that the University enhance its internal controls over compliance to ensure proper cost of attendance budgeting for all students and the cost of attendance information is properly documented.
Views of Responsible Officials – There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance.
A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record.