FAC Explorer

Audit 323625

FY End
2024-06-30
Total Expended
$83.17M
Findings
8
Programs
55
Organization: Florida Institute of Technology, Inc. (FL)
Year: 2024 Accepted: 2024-10-02
Auditor: Berman Hopkins Wright & Laham CPAS and Associates LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
501570 2024-001 Significant Deficiency - N
501571 2024-001 Significant Deficiency - N
501572 2024-001 Significant Deficiency - N
501573 2024-001 Significant Deficiency - N
1078012 2024-001 Significant Deficiency - N
1078013 2024-001 Significant Deficiency - N
1078014 2024-001 Significant Deficiency - N
1078015 2024-001 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $60.15M Yes 1
84.063 Federal Pell Grant Program $6.75M Yes 1
64.028 Post-9/11 Veterans Educational Assistance $5.65M - 0
84.007 Federal Supplemental Educational Opportunity Grants $718,821 Yes 1
84.033 Federal Work-Study Program $672,514 Yes 1
11.431 Climate and Atmospheric Research $251,490 Yes 0
12.330 Science, Technology, Engineering & Mathematics (stem) Education, Outreach and Workforce Program $240,166 Yes 0
93.958 Block Grants for Community Mental Health Services $223,740 Yes 0
10.215 Sustainable Agriculture Research and Education $200,536 Yes 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $190,733 Yes 0
47.075 Social, Behavioral, and Economic Sciences $161,844 Yes 0
93.865 Child Health and Human Development Extramural Research $150,739 Yes 0
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $125,292 Yes 0
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $113,119 Yes 0
11.609 Measurement and Engineering Research and Standards $103,245 Yes 0
66.484 Geographic Programs - South Florida Geographic Initiatives Program $97,834 Yes 0
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $89,986 Yes 0
12.800 Air Force Defense Research Sciences Program $76,296 Yes 0
11.417 Sea Grant Support $72,995 Yes 0
81.049 Office of Science Financial Assistance Program $71,748 Yes 0
11.454 Unallied Management Projects $55,599 Yes 0
20.200 Highway Research and Development Program $54,935 Yes 0
45.149 Promotion of the Humanities Division of Preservation and Access $51,177 - 0
11.427 Fisheries Development and Utilization Research and Development Grants and Cooperative Agreements Program $45,150 Yes 0
43.001 Science $43,181 Yes 0
47.049 Mathematical and Physical Sciences $42,236 Yes 0
15.628 Multistate Conservation Grant $41,158 Yes 0
43.003 Exploration $40,982 Yes 0
59.043 Women's Business Ownership Assistance $40,682 - 0
47.076 Stem Education (formerly Education and Human Resources) $35,277 Yes 0
20.108 Aviation Research Grants $33,891 Yes 0
10.310 Agriculture and Food Research Initiative (afri) $30,896 Yes 0
93.191 Graduate Psychology Education $29,673 - 0
66.456 National Estuary Program $28,521 Yes 0
12.630 Basic, Applied, and Advanced Research in Science and Engineering $27,815 Yes 0
43.008 Office of Stem Engagement (ostem) $24,886 Yes 0
93.859 Biomedical Research and Research Training $22,375 Yes 0
20.109 Air Transportation Centers of Excellence $22,214 Yes 0
93.RD2 Als $21,409 Yes 0
43.002 Aeronautics $21,153 Yes 0
15.945 Cooperative Research and Training Programs � Resources of the National Park System $20,744 Yes 0
12.910 Research and Technology Development $19,116 Yes 0
16.301 Law Enforcement Assistance FBI Crime Laboratory Support $18,074 Yes 0
16.575 Crime Victim Assistance $10,833 - 0
11.439 Marine Mammal Data Program $10,369 Yes 0
43.012 Space Technology $8,770 Yes 0
43.009 Mission Support $8,534 Yes 0
98.001 Usaid Foreign Assistance for Programs Overseas $8,397 Yes 0
47.041 Engineering $7,373 Yes 0
47.074 Biological Sciences $6,220 Yes 0
47.RD1 Engineering $5,770 Yes 0
12.300 Basic and Applied Scientific Research $5,229 Yes 0
47.050 Geosciences $3,127 Yes 0
11.012 Integrated Ocean Observing System (ioos) $457 Yes 0
93.396 Cancer Biology Research $78 Yes 0

Contacts

Name Title Type
WNN6VH618X58 Wendy Murrell Auditee
3216748837 Laura Anne Pray Auditor
No contacts on file

Notes to SEFA

Title: 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: Basis of Presentation - The accompanying schedule of expenditures of federal awards and state financial assistance summarizes the expenditures incurred under all federal and state awards received by Florida Institute of Technology, Inc. (the “University”) for the year ended June 30, 2024. For purposes of this schedule, federal awards and state projects include all grants, contracts, loans, and loan guarantee agreements entered into directly between the University and agencies and departments of the federal and state government and federal and state awards passed through other agencies. Expenditures for federal and state awards programs are recognized on the accrual basis of accounting. The information on this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and Chapter 10.650, Rules of the Auditor General; therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: Under the current federally negotiated rate agreement, the University uses a predetermined indirect cost rate using a modified total direct cost base. This rate is in effect until June 30, 2026. The University applies a 44.87% indirect cost rate or a 28.45% off campus rate on a modified total direct cost basis to all federal grants, unless otherwise restricted by the agency. Basis of Presentation - The accompanying schedule of expenditures of federal awards and state financial assistance summarizes the expenditures incurred under all federal and state awards received by Florida Institute of Technology, Inc. (the “University”) for the year ended June 30, 2024. For purposes of this schedule, federal awards and state projects include all grants, contracts, loans, and loan guarantee agreements entered into directly between the University and agencies and departments of the federal and state government and federal and state awards passed through other agencies. Expenditures for federal and state awards programs are recognized on the accrual basis of accounting. The information on this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and Chapter 10.650, Rules of the Auditor General; therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements.
Title: 2. PROGRAM CLUSTERS Accounting Policies: Basis of Presentation - The accompanying schedule of expenditures of federal awards and state financial assistance summarizes the expenditures incurred under all federal and state awards received by Florida Institute of Technology, Inc. (the “University”) for the year ended June 30, 2024. For purposes of this schedule, federal awards and state projects include all grants, contracts, loans, and loan guarantee agreements entered into directly between the University and agencies and departments of the federal and state government and federal and state awards passed through other agencies. Expenditures for federal and state awards programs are recognized on the accrual basis of accounting. The information on this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and Chapter 10.650, Rules of the Auditor General; therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: Under the current federally negotiated rate agreement, the University uses a predetermined indirect cost rate using a modified total direct cost base. This rate is in effect until June 30, 2026. The University applies a 44.87% indirect cost rate or a 28.45% off campus rate on a modified total direct cost basis to all federal grants, unless otherwise restricted by the agency. Federal Uniform Guidance and the Florida State Single Audit Act define a cluster of programs as a grouping of closely related programs that share common compliance requirements. According to this definition, we have determined the Student Financial Assistance Programs and Research and Development Programs to be Federal clusters of programs and the Florida Student Financial Assistance to be a State cluster of programs.
Title: 3. LOANS OUTSTANDING Accounting Policies: Basis of Presentation - The accompanying schedule of expenditures of federal awards and state financial assistance summarizes the expenditures incurred under all federal and state awards received by Florida Institute of Technology, Inc. (the “University”) for the year ended June 30, 2024. For purposes of this schedule, federal awards and state projects include all grants, contracts, loans, and loan guarantee agreements entered into directly between the University and agencies and departments of the federal and state government and federal and state awards passed through other agencies. Expenditures for federal and state awards programs are recognized on the accrual basis of accounting. The information on this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and Chapter 10.650, Rules of the Auditor General; therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: Under the current federally negotiated rate agreement, the University uses a predetermined indirect cost rate using a modified total direct cost base. This rate is in effect until June 30, 2026. The University applies a 44.87% indirect cost rate or a 28.45% off campus rate on a modified total direct cost basis to all federal grants, unless otherwise restricted by the agency. The University had the following loan balances due to the federal government at June 30, 2024: See the Notes to the SEFA for Chart / table
Title: 4. GUARANTEED STUDENT LOAN PROGRAMS Accounting Policies: Basis of Presentation - The accompanying schedule of expenditures of federal awards and state financial assistance summarizes the expenditures incurred under all federal and state awards received by Florida Institute of Technology, Inc. (the “University”) for the year ended June 30, 2024. For purposes of this schedule, federal awards and state projects include all grants, contracts, loans, and loan guarantee agreements entered into directly between the University and agencies and departments of the federal and state government and federal and state awards passed through other agencies. Expenditures for federal and state awards programs are recognized on the accrual basis of accounting. The information on this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and Chapter 10.650, Rules of the Auditor General; therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: Under the current federally negotiated rate agreement, the University uses a predetermined indirect cost rate using a modified total direct cost base. This rate is in effect until June 30, 2026. The University applies a 44.87% indirect cost rate or a 28.45% off campus rate on a modified total direct cost basis to all federal grants, unless otherwise restricted by the agency. During the year ended June 30, 2024, the University processed new loans under the following Guaranteed Student Loan Programs: See the Notes to the SEFA for Chart / table
Title: 5. CONTINGENCY Accounting Policies: Basis of Presentation - The accompanying schedule of expenditures of federal awards and state financial assistance summarizes the expenditures incurred under all federal and state awards received by Florida Institute of Technology, Inc. (the “University”) for the year ended June 30, 2024. For purposes of this schedule, federal awards and state projects include all grants, contracts, loans, and loan guarantee agreements entered into directly between the University and agencies and departments of the federal and state government and federal and state awards passed through other agencies. Expenditures for federal and state awards programs are recognized on the accrual basis of accounting. The information on this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and Chapter 10.650, Rules of the Auditor General; therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: Under the current federally negotiated rate agreement, the University uses a predetermined indirect cost rate using a modified total direct cost base. This rate is in effect until June 30, 2026. The University applies a 44.87% indirect cost rate or a 28.45% off campus rate on a modified total direct cost basis to all federal grants, unless otherwise restricted by the agency. The grant revenue amounts received are subject to audit and adjustment. If any expenditures are disallowed by the grantor agencies as a result of such an audit, any claim for reimbursement to the grantor agencies would become a liability of the University. In the opinion of management, all grant expenditures are in compliance with the terms of the grant agreements and applicable federal and state laws and regulations.
Title: 6. INDIRECT COST RATE Accounting Policies: Basis of Presentation - The accompanying schedule of expenditures of federal awards and state financial assistance summarizes the expenditures incurred under all federal and state awards received by Florida Institute of Technology, Inc. (the “University”) for the year ended June 30, 2024. For purposes of this schedule, federal awards and state projects include all grants, contracts, loans, and loan guarantee agreements entered into directly between the University and agencies and departments of the federal and state government and federal and state awards passed through other agencies. Expenditures for federal and state awards programs are recognized on the accrual basis of accounting. The information on this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and Chapter 10.650, Rules of the Auditor General; therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: Under the current federally negotiated rate agreement, the University uses a predetermined indirect cost rate using a modified total direct cost base. This rate is in effect until June 30, 2026. The University applies a 44.87% indirect cost rate or a 28.45% off campus rate on a modified total direct cost basis to all federal grants, unless otherwise restricted by the agency. Under the current federally negotiated rate agreement, the University uses a predetermined indirect cost rate using a modified total direct cost base. This rate is in effect until June 30, 2026. The University applies a 44.87% indirect cost rate or a 28.45% off campus rate on a modified total direct cost basis to all federal grants, unless otherwise restricted by the agency.

Finding Details

Finding 2024-001
2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control Criteria In accordance with 34 CFR 668.22, 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, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.
Finding 2024-001
2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control Criteria In accordance with 34 CFR 668.22, 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, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.
Finding 2024-001
2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control Criteria In accordance with 34 CFR 668.22, 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, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.
Finding 2024-001
2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control Criteria In accordance with 34 CFR 668.22, 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, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.
Finding 2024-001
2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control Criteria In accordance with 34 CFR 668.22, 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, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.
Finding 2024-001
2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control Criteria In accordance with 34 CFR 668.22, 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, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.
Finding 2024-001
2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control Criteria In accordance with 34 CFR 668.22, 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, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.
Finding 2024-001
2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control Criteria In accordance with 34 CFR 668.22, 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, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.