Federal Agency Program – U.S. Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268
Program Year - June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests – Return of Title IV Funds – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – During our testing, we noted two students who should have a return of funds calculation completed and submitted but it did not occur (at time of testing).
Questioned Costs – $28,000
Context – During our testing, it was noted that the University does have a process in place to ensure return of calculations are being performed, but there was a break-down in the communication process during the year. Of a sample of ten return of funds tested from a population of 61 performed during the examination period, two calculations were not performed at time of fieldwork. Our sample was not, and was not intended to be, statistically valid.
Cause – The process of communicating a withdrawal to the party responsible for the refund did not occur.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University has a policy in place to review the return of funds calculation and ensure that the calculation is accurate according to the regulations to be diligent in performing secondary reviews to endure the calculations are performed correctly.
Views of Responsible Officials and Planned Corrective Action – Due to previous manual processes and significant staffing turnover in the Accounting and Financial Aid areas, this summer, we discovered some of the R2T4 calculations were missed. Once this was discovered, we went back through and ensured all the withdrawal calculations were done and funds returned, even though they were outside the compliance timeframe.
While testing the return of Title IV funds from a sample, FORVIS noted that two students did not have a refund calculation completed in a timely manner. These findings had been discovered by SBU and corrected, and funds were returned earlier, but they were still outside the compliance timeframe, which required an audit finding.
To address these issues, SBU employees have taken the following corrective measures:
1. We reworked the reporting process for withdrawals. All withdrawals now go to the Associate Provost regardless of campus or program. They are then processed by the Registrar’s Office and placed in a shared drive. Once there, they are reviewed weekly by the Financial Aid Office, and R2T4s are completed in a timely manner. This process no longer relies on a member of the Accounting Office to notify Financial Aid of a withdrawal.
2. R2T4 requests are completed by one Financial Aid staff member and verified and processed by another to ensure accuracy and reliability.
3. We have implemented an administrative withdrawal process to give campus and program directors the ability and authority to withdraw students who are no longer in attendance to limit the number of all Fs at the end of the semester.
Federal Agency Program – U.S. Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268
Program Year - June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests – Return of Title IV Funds – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – During our testing, we noted two students who should have a return of funds calculation completed and submitted but it did not occur (at time of testing).
Questioned Costs – $28,000
Context – During our testing, it was noted that the University does have a process in place to ensure return of calculations are being performed, but there was a break-down in the communication process during the year. Of a sample of ten return of funds tested from a population of 61 performed during the examination period, two calculations were not performed at time of fieldwork. Our sample was not, and was not intended to be, statistically valid.
Cause – The process of communicating a withdrawal to the party responsible for the refund did not occur.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University has a policy in place to review the return of funds calculation and ensure that the calculation is accurate according to the regulations to be diligent in performing secondary reviews to endure the calculations are performed correctly.
Views of Responsible Officials and Planned Corrective Action – Due to previous manual processes and significant staffing turnover in the Accounting and Financial Aid areas, this summer, we discovered some of the R2T4 calculations were missed. Once this was discovered, we went back through and ensured all the withdrawal calculations were done and funds returned, even though they were outside the compliance timeframe.
While testing the return of Title IV funds from a sample, FORVIS noted that two students did not have a refund calculation completed in a timely manner. These findings had been discovered by SBU and corrected, and funds were returned earlier, but they were still outside the compliance timeframe, which required an audit finding.
To address these issues, SBU employees have taken the following corrective measures:
1. We reworked the reporting process for withdrawals. All withdrawals now go to the Associate Provost regardless of campus or program. They are then processed by the Registrar’s Office and placed in a shared drive. Once there, they are reviewed weekly by the Financial Aid Office, and R2T4s are completed in a timely manner. This process no longer relies on a member of the Accounting Office to notify Financial Aid of a withdrawal.
2. R2T4 requests are completed by one Financial Aid staff member and verified and processed by another to ensure accuracy and reliability.
3. We have implemented an administrative withdrawal process to give campus and program directors the ability and authority to withdraw students who are no longer in attendance to limit the number of all Fs at the end of the semester.
Federal Agency Program – U.S. Department of Education, Higher Education Emergency Relief Fund Strengthening Institutions Program, Assistance Listing Number 84.425M
Program Year - June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Cash Management – For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs. (2 CFR Section 200.305(b)).
Condition – During our testing, we noted the final draw of funds for the Strengthening Institutions Program was completed on November 8, 2022 while program costs funded by the draw were not incurred until December 2023.
Questioned Costs – N/A
Context – During our testing, it was noted that the University had one draw of funds under the program in the year ended May 31, 2023. The draw was completed in advance of disbursements for program costs, but was not as close as administratively feasible to the program disbursements.
Cause – The University's draw of program funding was not planned in a manner to minimize the time elapsing between the transfer of funds to the University and the disbursement by the University.
Effect – The University did not appropriately follow the requirements of 2 CFR 200.305(b) to time advance payments as close as is administratively feasible to the actual disbursement of program costs.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University review it's process for drawing down federal grant funding to ensure processes are consistent with federal requirements and individuals involved in drawing down funds are aware of the applicable requirements.
Views of Responsible Officials and Planned Corrective Action – Due to a turnover in the office of Controller, the grant was drawn down prematurely. While invoice and proposals were attained before the draw, the money was not expensed in the typical three to five days.
The controller who drew the money is no longer at the University. The current administration will return to normal University practice of not drawing down money until is it ready to be dispersed to the appropriate entity. This is normal practice for the University, but the practice was not followed due to a lack of knowledge. This has been corrected.
Federal Agency Program – U.S. Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268
Program Year - June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests – Return of Title IV Funds – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – During our testing, we noted two students who should have a return of funds calculation completed and submitted but it did not occur (at time of testing).
Questioned Costs – $28,000
Context – During our testing, it was noted that the University does have a process in place to ensure return of calculations are being performed, but there was a break-down in the communication process during the year. Of a sample of ten return of funds tested from a population of 61 performed during the examination period, two calculations were not performed at time of fieldwork. Our sample was not, and was not intended to be, statistically valid.
Cause – The process of communicating a withdrawal to the party responsible for the refund did not occur.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University has a policy in place to review the return of funds calculation and ensure that the calculation is accurate according to the regulations to be diligent in performing secondary reviews to endure the calculations are performed correctly.
Views of Responsible Officials and Planned Corrective Action – Due to previous manual processes and significant staffing turnover in the Accounting and Financial Aid areas, this summer, we discovered some of the R2T4 calculations were missed. Once this was discovered, we went back through and ensured all the withdrawal calculations were done and funds returned, even though they were outside the compliance timeframe.
While testing the return of Title IV funds from a sample, FORVIS noted that two students did not have a refund calculation completed in a timely manner. These findings had been discovered by SBU and corrected, and funds were returned earlier, but they were still outside the compliance timeframe, which required an audit finding.
To address these issues, SBU employees have taken the following corrective measures:
1. We reworked the reporting process for withdrawals. All withdrawals now go to the Associate Provost regardless of campus or program. They are then processed by the Registrar’s Office and placed in a shared drive. Once there, they are reviewed weekly by the Financial Aid Office, and R2T4s are completed in a timely manner. This process no longer relies on a member of the Accounting Office to notify Financial Aid of a withdrawal.
2. R2T4 requests are completed by one Financial Aid staff member and verified and processed by another to ensure accuracy and reliability.
3. We have implemented an administrative withdrawal process to give campus and program directors the ability and authority to withdraw students who are no longer in attendance to limit the number of all Fs at the end of the semester.
Federal Agency Program – U.S. Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268
Program Year - June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Special Tests – Return of Title IV Funds – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)).
Condition – During our testing, we noted two students who should have a return of funds calculation completed and submitted but it did not occur (at time of testing).
Questioned Costs – $28,000
Context – During our testing, it was noted that the University does have a process in place to ensure return of calculations are being performed, but there was a break-down in the communication process during the year. Of a sample of ten return of funds tested from a population of 61 performed during the examination period, two calculations were not performed at time of fieldwork. Our sample was not, and was not intended to be, statistically valid.
Cause – The process of communicating a withdrawal to the party responsible for the refund did not occur.
Effect – The University returned the incorrect amount of funds to the Department of Education.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University has a policy in place to review the return of funds calculation and ensure that the calculation is accurate according to the regulations to be diligent in performing secondary reviews to endure the calculations are performed correctly.
Views of Responsible Officials and Planned Corrective Action – Due to previous manual processes and significant staffing turnover in the Accounting and Financial Aid areas, this summer, we discovered some of the R2T4 calculations were missed. Once this was discovered, we went back through and ensured all the withdrawal calculations were done and funds returned, even though they were outside the compliance timeframe.
While testing the return of Title IV funds from a sample, FORVIS noted that two students did not have a refund calculation completed in a timely manner. These findings had been discovered by SBU and corrected, and funds were returned earlier, but they were still outside the compliance timeframe, which required an audit finding.
To address these issues, SBU employees have taken the following corrective measures:
1. We reworked the reporting process for withdrawals. All withdrawals now go to the Associate Provost regardless of campus or program. They are then processed by the Registrar’s Office and placed in a shared drive. Once there, they are reviewed weekly by the Financial Aid Office, and R2T4s are completed in a timely manner. This process no longer relies on a member of the Accounting Office to notify Financial Aid of a withdrawal.
2. R2T4 requests are completed by one Financial Aid staff member and verified and processed by another to ensure accuracy and reliability.
3. We have implemented an administrative withdrawal process to give campus and program directors the ability and authority to withdraw students who are no longer in attendance to limit the number of all Fs at the end of the semester.
Federal Agency Program – U.S. Department of Education, Higher Education Emergency Relief Fund Strengthening Institutions Program, Assistance Listing Number 84.425M
Program Year - June 1, 2022 – May 31, 2023
Criteria or Specific Requirement – Cash Management – For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs. (2 CFR Section 200.305(b)).
Condition – During our testing, we noted the final draw of funds for the Strengthening Institutions Program was completed on November 8, 2022 while program costs funded by the draw were not incurred until December 2023.
Questioned Costs – N/A
Context – During our testing, it was noted that the University had one draw of funds under the program in the year ended May 31, 2023. The draw was completed in advance of disbursements for program costs, but was not as close as administratively feasible to the program disbursements.
Cause – The University's draw of program funding was not planned in a manner to minimize the time elapsing between the transfer of funds to the University and the disbursement by the University.
Effect – The University did not appropriately follow the requirements of 2 CFR 200.305(b) to time advance payments as close as is administratively feasible to the actual disbursement of program costs.
Identification as a Repeat Finding – N/A
Recommendation – We recommend that the University review it's process for drawing down federal grant funding to ensure processes are consistent with federal requirements and individuals involved in drawing down funds are aware of the applicable requirements.
Views of Responsible Officials and Planned Corrective Action – Due to a turnover in the office of Controller, the grant was drawn down prematurely. While invoice and proposals were attained before the draw, the money was not expensed in the typical three to five days.
The controller who drew the money is no longer at the University. The current administration will return to normal University practice of not drawing down money until is it ready to be dispersed to the appropriate entity. This is normal practice for the University, but the practice was not followed due to a lack of knowledge. This has been corrected.