Eastern Oklahoma State CollegeState Government

Criteria: Per 34 CFR, Section 674, Federal Work-Study Program, schools participating in FWS (Federal Work Study) and FSEOG (Federal Supplemental Educational Opportunity Grant) a College must provide an institutional share as a match for its federal allocation received, with the minimum requirement being 25% of the total funds received. Although a College is required to match its federal allocation, there is a waiver that some schools are eligible for, under Sections A and B of Titles III and V of the Higher Education Act of 1965. Condition: Although the College usually qualifies for the match waiver, during fiscal year 2024 the College did not obtain the letter confirming the waiver. Therefore, the College was required to provide a 25% match of FWS and FSEOG funds. The total related federal expenses for the year totaled $168,372 from FWS and FSEOG funds, of which the College should have matched a total of $42,093; however, the College only matched approximately 21% utilizing local funds. Cause and Effect: As a result of inadequate reviews of the College’s matching requirements for its federal grants received and the absence of a waiver, the College was not in compliance with 24 CFR Section 674. The College missed its required match for a total of 43 students during fiscal year 2024. Recommendation: We recommend obtaining the available waiver prior to the start of the fiscal year, or prior to approving the upcoming year budget. A proactive approach will avoid any incidents of possible noncompliance related to matching FWS and FSEG funds in the future.

Criteria: Per 2 CFR Part 200 Appendix A, Section IV of the Uniform Guidance; Student Financial Assistance (SFA) Programs, the determination of need based SFA award amounts is based on financial need. Financial need is defined as the student’s cost of attendance (COA) minus the student’s expected family contribution (EFC) (as computed by the central processor and included on the student’s SAR/ISIR). Once a student is awarded any financialaid, to find remaining financial need one would use the following formula – COA minus EFC minus Estimated Financial Assistance (EFA) (§ 668.2) equals remaining need. To avoid overpayments, need-based SFA awardscannot exceed the student’s overall financial need. Condition: A student received a direct subsidized loan despite showing no financial need, as the student’s EFC was higher than the student’s COA. The student’s EFC was determined to be $24,282, whereas their COA was $20,686. Despite no financial need existing, the student was awarded a direct subsidized loan of $3,500, resulting in an over award. Cause and Effect: As a result of inadequate reviews of student’s financial need during the application process, the College awarded a direct subsidized loan to an ineligible student as no EFA existed for this individual. Recommendation: We recommend that management implements a more thorough review of individual student files before distribution of direct subsidized loans and other need based SFA awards. This review process should include a careful examination of each student’s EFC and COA to ensure that only eligible students receive needbased aid. Management Response: Management agrees this student had an incorrect type of loan awarded. Based off the students EFC number the loan should have been an unsubsidized loan and not the subsidized loan. The Financial Aid office will make the corrections of the loan type to the student’s account. Financial Aid will add an internal control process to ensure there is a second verification of student federal loans in place.

Criteria: The Payment and Disbursement Schedules established by the U.S. Department of Education sets forth the determining amounts of 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 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 34 CFR 668.2(b) states, for a program that measures progress in credit hours and uses standard terms (semesters, trimesters, or quarters), 12 semester hours or 12 quarter hours per academic term as a full-time student. Condition: A qualifying student was awarded a Federal Pell Grant for the Fall semester as a full-time student. Upon review of the student’s transcript, it showed the student was enrolled in 10 credit hours, categorizing the student as a three-quarter time student, therefore, an over award of Pell occurred. Cause and Effect: When a student’s withdrawal from a course is prior to the census date in the College’s student management system, the dropped course noted per the Registrar’s office will automatically remove the credit hours for the course dropped. If, however, this occurs after the census date, a manual adjustment to the enrollment credits screen is required. Although the dropped course was appropriately reflected for financial aid, direct loans, and Title IV, it was overlooked in the student management system for Pell credits. As a result, an over awarded occurred as the student was treated as full time rather than as three quarters time for Pell. Recommendation: We recommend that management reconciles student transcripts final credit hours to the credit hours noted in the student management system to ensure awarded Pell grants are at the appropriate amount. Management Response: We concur with this finding and have reinforced with enrollment staff the internal control procedures to ensure the proper process is followed for students who withdraw or are considered no-shows. The enterprise management system for the College should adjust the credit hours for all dropped courses. Due to the student being administratively withdrawn after the last day to drop courses our system did not adjust these courses from the student financial aid aspect. We are aware of this and working toward ensuring this does not occur in the future. We will be scheduling additional training with our system in the upcoming year address this.

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