ED - A20IL0007 - 1.2

We recommend that the Chief Operating Officer for Federal Student Aid (FSA) require USC to— 1.2 Review its records forthe 6,062 students for whom the school reported that it applied professional judgment other than dependency override foraward year 2019–2020 or award year 2020–2021 but were not included in our sample and (a) identify those students forwhom it improperly adjusted the value of data items affecting AGI based on allowances or expenses unrelated to specialcircumstances, (b) provide FSA with a listing of the improperly disbursed Title IV funds and the records associated withthose students for whom financial aid administrators improperly applied professional judgment, and (c) return theimproperly disbursed Title IV funds to the Department.