Finding 2024-001
Student Financial Aid Cluster
Cash Management
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster – (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have documented controls in place to ensure that drawdown requests for SFA Title IV funds do not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The documented controls in place should also ensure that any excess cash over the tolerable amount of one percent of the total amount of funds drawn by the institution in the prior award year and any amount remaining is returned to the Department of Education within seven days.
Condition: WCCC requests funds from the Department of Education under the Advance Payment Method. As permitted, WCCC elects to post Title IV disbursements prior to drawing funds. Although, WCCC draws funds after the SFA Title IV disbursements are posted, they are still responsible for ensuring funds were not drawn in excess of the tolerable amount and that any funds that were drawn in excess were returned within the required seven days. A documented reconciliation between the funds drawn and the funds disbursed could not be provided by WCCC. In addition, documented controls were not in place to ensure any excess cash over the tolerable amount of one percent and any remaining amounts were returned to the Department of Education within seven days. The results of our testing of Title IV draws did not identify instances in which draws exceeded disbursements by amounts in excess of the allowable one percent threshold.
Cause: Documented controls were not in place to ensure WCCC complied with the cash management requirements under the Advance Payment Method for SFA Title IV funds. WCCC implemented a new student financial aid module in March 2023 and documented procedures to address drawdown reconciliations are still being addressed.
Effect: Lack of documented controls of drawdown requests could result in excess funds being drawn and not returned to the Department of Education within the required timeframe.
Repeat Finding: This is not a repeat finding.
Questioned costs: None
Recommendation: We recommend that WCCC implement a clear, contemporaneously documented trail regarding the reconciliation process to ensure the SFA Title IV draws do not exceed SFA Title IV disbursements posted to student accounts. This documented process should include controls to ensure that any excess funds over the tolerable amount are returned to the Department of Education within the required seven days.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-001
Student Financial Aid Cluster
Cash Management
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster – (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have documented controls in place to ensure that drawdown requests for SFA Title IV funds do not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The documented controls in place should also ensure that any excess cash over the tolerable amount of one percent of the total amount of funds drawn by the institution in the prior award year and any amount remaining is returned to the Department of Education within seven days.
Condition: WCCC requests funds from the Department of Education under the Advance Payment Method. As permitted, WCCC elects to post Title IV disbursements prior to drawing funds. Although, WCCC draws funds after the SFA Title IV disbursements are posted, they are still responsible for ensuring funds were not drawn in excess of the tolerable amount and that any funds that were drawn in excess were returned within the required seven days. A documented reconciliation between the funds drawn and the funds disbursed could not be provided by WCCC. In addition, documented controls were not in place to ensure any excess cash over the tolerable amount of one percent and any remaining amounts were returned to the Department of Education within seven days. The results of our testing of Title IV draws did not identify instances in which draws exceeded disbursements by amounts in excess of the allowable one percent threshold.
Cause: Documented controls were not in place to ensure WCCC complied with the cash management requirements under the Advance Payment Method for SFA Title IV funds. WCCC implemented a new student financial aid module in March 2023 and documented procedures to address drawdown reconciliations are still being addressed.
Effect: Lack of documented controls of drawdown requests could result in excess funds being drawn and not returned to the Department of Education within the required timeframe.
Repeat Finding: This is not a repeat finding.
Questioned costs: None
Recommendation: We recommend that WCCC implement a clear, contemporaneously documented trail regarding the reconciliation process to ensure the SFA Title IV draws do not exceed SFA Title IV disbursements posted to student accounts. This documented process should include controls to ensure that any excess funds over the tolerable amount are returned to the Department of Education within the required seven days.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-001
Student Financial Aid Cluster
Cash Management
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster – (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have documented controls in place to ensure that drawdown requests for SFA Title IV funds do not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The documented controls in place should also ensure that any excess cash over the tolerable amount of one percent of the total amount of funds drawn by the institution in the prior award year and any amount remaining is returned to the Department of Education within seven days.
Condition: WCCC requests funds from the Department of Education under the Advance Payment Method. As permitted, WCCC elects to post Title IV disbursements prior to drawing funds. Although, WCCC draws funds after the SFA Title IV disbursements are posted, they are still responsible for ensuring funds were not drawn in excess of the tolerable amount and that any funds that were drawn in excess were returned within the required seven days. A documented reconciliation between the funds drawn and the funds disbursed could not be provided by WCCC. In addition, documented controls were not in place to ensure any excess cash over the tolerable amount of one percent and any remaining amounts were returned to the Department of Education within seven days. The results of our testing of Title IV draws did not identify instances in which draws exceeded disbursements by amounts in excess of the allowable one percent threshold.
Cause: Documented controls were not in place to ensure WCCC complied with the cash management requirements under the Advance Payment Method for SFA Title IV funds. WCCC implemented a new student financial aid module in March 2023 and documented procedures to address drawdown reconciliations are still being addressed.
Effect: Lack of documented controls of drawdown requests could result in excess funds being drawn and not returned to the Department of Education within the required timeframe.
Repeat Finding: This is not a repeat finding.
Questioned costs: None
Recommendation: We recommend that WCCC implement a clear, contemporaneously documented trail regarding the reconciliation process to ensure the SFA Title IV draws do not exceed SFA Title IV disbursements posted to student accounts. This documented process should include controls to ensure that any excess funds over the tolerable amount are returned to the Department of Education within the required seven days.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-001
Student Financial Aid Cluster
Cash Management
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster – (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have documented controls in place to ensure that drawdown requests for SFA Title IV funds do not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The documented controls in place should also ensure that any excess cash over the tolerable amount of one percent of the total amount of funds drawn by the institution in the prior award year and any amount remaining is returned to the Department of Education within seven days.
Condition: WCCC requests funds from the Department of Education under the Advance Payment Method. As permitted, WCCC elects to post Title IV disbursements prior to drawing funds. Although, WCCC draws funds after the SFA Title IV disbursements are posted, they are still responsible for ensuring funds were not drawn in excess of the tolerable amount and that any funds that were drawn in excess were returned within the required seven days. A documented reconciliation between the funds drawn and the funds disbursed could not be provided by WCCC. In addition, documented controls were not in place to ensure any excess cash over the tolerable amount of one percent and any remaining amounts were returned to the Department of Education within seven days. The results of our testing of Title IV draws did not identify instances in which draws exceeded disbursements by amounts in excess of the allowable one percent threshold.
Cause: Documented controls were not in place to ensure WCCC complied with the cash management requirements under the Advance Payment Method for SFA Title IV funds. WCCC implemented a new student financial aid module in March 2023 and documented procedures to address drawdown reconciliations are still being addressed.
Effect: Lack of documented controls of drawdown requests could result in excess funds being drawn and not returned to the Department of Education within the required timeframe.
Repeat Finding: This is not a repeat finding.
Questioned costs: None
Recommendation: We recommend that WCCC implement a clear, contemporaneously documented trail regarding the reconciliation process to ensure the SFA Title IV draws do not exceed SFA Title IV disbursements posted to student accounts. This documented process should include controls to ensure that any excess funds over the tolerable amount are returned to the Department of Education within the required seven days.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-002
Student Financial Aid Cluster
Allowable Costs and Allowable Activities and Eligibility
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need. These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts.
Condition: Our financial aid sample of 40 items tested yielded 29 students who received Pell Grant Funding. Of the 29 students who received Pell Grant funding, we noted 1 instance where the student received the incorrect amount of Pell funding. Based on the students expected family contribution, the student should have received $925 in Pell funding; however, they only received $631 in Pell funding, resulting in an underpayment of Pell funding of $294. Of the 40 students selected for testing, WCCC was also not able to provide documentation of the calculations performed to determine each student’s cost of attendance for all 40 students. Additionally, the cost of attendance amounts within the newly implemented enterprise-wide system student financial aid module could not be relied upon to reperform calculations to determine proper award amounts. Cost of attendance calculations were done by the auditors for the 40 individuals selected for testing to determine if the award amounts were appropriate.
Cause: Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to. As a result of system changes, cost of attendance calculations within the system could not be relied upon and WCCC did not maintain documentation for the manual cost of attendance calculations performed at the time students were awarded financial assistance.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for.
Repeat Finding: This is a repeat finding of 2023-003.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant fund and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-002
Student Financial Aid Cluster
Allowable Costs and Allowable Activities and Eligibility
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need. These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts.
Condition: Our financial aid sample of 40 items tested yielded 29 students who received Pell Grant Funding. Of the 29 students who received Pell Grant funding, we noted 1 instance where the student received the incorrect amount of Pell funding. Based on the students expected family contribution, the student should have received $925 in Pell funding; however, they only received $631 in Pell funding, resulting in an underpayment of Pell funding of $294. Of the 40 students selected for testing, WCCC was also not able to provide documentation of the calculations performed to determine each student’s cost of attendance for all 40 students. Additionally, the cost of attendance amounts within the newly implemented enterprise-wide system student financial aid module could not be relied upon to reperform calculations to determine proper award amounts. Cost of attendance calculations were done by the auditors for the 40 individuals selected for testing to determine if the award amounts were appropriate.
Cause: Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to. As a result of system changes, cost of attendance calculations within the system could not be relied upon and WCCC did not maintain documentation for the manual cost of attendance calculations performed at the time students were awarded financial assistance.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for.
Repeat Finding: This is a repeat finding of 2023-003.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant fund and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-002
Student Financial Aid Cluster
Allowable Costs and Allowable Activities and Eligibility
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need. These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts.
Condition: Our financial aid sample of 40 items tested yielded 29 students who received Pell Grant Funding. Of the 29 students who received Pell Grant funding, we noted 1 instance where the student received the incorrect amount of Pell funding. Based on the students expected family contribution, the student should have received $925 in Pell funding; however, they only received $631 in Pell funding, resulting in an underpayment of Pell funding of $294. Of the 40 students selected for testing, WCCC was also not able to provide documentation of the calculations performed to determine each student’s cost of attendance for all 40 students. Additionally, the cost of attendance amounts within the newly implemented enterprise-wide system student financial aid module could not be relied upon to reperform calculations to determine proper award amounts. Cost of attendance calculations were done by the auditors for the 40 individuals selected for testing to determine if the award amounts were appropriate.
Cause: Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to. As a result of system changes, cost of attendance calculations within the system could not be relied upon and WCCC did not maintain documentation for the manual cost of attendance calculations performed at the time students were awarded financial assistance.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for.
Repeat Finding: This is a repeat finding of 2023-003.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant fund and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-002
Student Financial Aid Cluster
Allowable Costs and Allowable Activities and Eligibility
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need. These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts.
Condition: Our financial aid sample of 40 items tested yielded 29 students who received Pell Grant Funding. Of the 29 students who received Pell Grant funding, we noted 1 instance where the student received the incorrect amount of Pell funding. Based on the students expected family contribution, the student should have received $925 in Pell funding; however, they only received $631 in Pell funding, resulting in an underpayment of Pell funding of $294. Of the 40 students selected for testing, WCCC was also not able to provide documentation of the calculations performed to determine each student’s cost of attendance for all 40 students. Additionally, the cost of attendance amounts within the newly implemented enterprise-wide system student financial aid module could not be relied upon to reperform calculations to determine proper award amounts. Cost of attendance calculations were done by the auditors for the 40 individuals selected for testing to determine if the award amounts were appropriate.
Cause: Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to. As a result of system changes, cost of attendance calculations within the system could not be relied upon and WCCC did not maintain documentation for the manual cost of attendance calculations performed at the time students were awarded financial assistance.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for.
Repeat Finding: This is a repeat finding of 2023-003.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant fund and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-003
Student Financial Aid Cluster
Special Tests and Provisions – Return of Title IV Funds
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs. Return of Title IV funds are required to be deposited or transferred into the Student Financial Aid Account or electronic fund transfers initiated to the Department of Education no later than 45 days after the date the institution determined that the student withdrew.
Condition: Our Return of Title IV Funds sample of 25 yielded three instances where the improper amount of funding was returned to the Department of Education. The calculation of the Return of Title IV Funds for the first student was based on a withdrawal date of February 5, 2024 when the actual withdrawal date was March 25, 2024. Based on the withdrawal date utilized in the calculation, WCCC returned a total of $1,023 of the subsidized loan award; however, based on the actual withdrawal date, the amount that should have been returned was $495.18, resulting in an overpayment of $527.82. The calculation of the Return of Title IV Funds for the second student did not include the unsubsidized loan in the calculation. The amount of Title IV Funds returned was $1,096, but had the unsubsidized loan been included in the calculation, only $747.18 should have been returned, resulting in an overpayment of $348.82. The calculation of the return of Title IV Funds for the third student, calculated a required return of Pell funding in the amount of $599.67. While the calculation of the return was correct, the amount calculated was not returned to the Department of Education, resulting in an underpayment of $599.67. Additionally, our Return of Title IV Funds sample of 25 yielded five instances in which the calculation was not performed within 45 days of the students’ withdrawal dates. As a result, $2,788.31 of funds were not returned timely to the Department of Education.
Cause: Controls were not in place to ensure that Return of Title IV Funds were performed accurately and timely.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC. Additionally, calculations were not performed timely. As a result, WCCC did not comply with requirements related to the calculation and timely return of Title IV Funds as outlined in 34 CFR section 668.22.
Repeat Finding: This is a repeat finding of 2023-004.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review, including reperformance of the calculations of the refund calculations to ensure calculations are being performed properly. In addition, we recommend that WCCC develop a process for ensuring calculations and subsequently, return of Title IV funding is done timely.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-003
Student Financial Aid Cluster
Special Tests and Provisions – Return of Title IV Funds
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs. Return of Title IV funds are required to be deposited or transferred into the Student Financial Aid Account or electronic fund transfers initiated to the Department of Education no later than 45 days after the date the institution determined that the student withdrew.
Condition: Our Return of Title IV Funds sample of 25 yielded three instances where the improper amount of funding was returned to the Department of Education. The calculation of the Return of Title IV Funds for the first student was based on a withdrawal date of February 5, 2024 when the actual withdrawal date was March 25, 2024. Based on the withdrawal date utilized in the calculation, WCCC returned a total of $1,023 of the subsidized loan award; however, based on the actual withdrawal date, the amount that should have been returned was $495.18, resulting in an overpayment of $527.82. The calculation of the Return of Title IV Funds for the second student did not include the unsubsidized loan in the calculation. The amount of Title IV Funds returned was $1,096, but had the unsubsidized loan been included in the calculation, only $747.18 should have been returned, resulting in an overpayment of $348.82. The calculation of the return of Title IV Funds for the third student, calculated a required return of Pell funding in the amount of $599.67. While the calculation of the return was correct, the amount calculated was not returned to the Department of Education, resulting in an underpayment of $599.67. Additionally, our Return of Title IV Funds sample of 25 yielded five instances in which the calculation was not performed within 45 days of the students’ withdrawal dates. As a result, $2,788.31 of funds were not returned timely to the Department of Education.
Cause: Controls were not in place to ensure that Return of Title IV Funds were performed accurately and timely.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC. Additionally, calculations were not performed timely. As a result, WCCC did not comply with requirements related to the calculation and timely return of Title IV Funds as outlined in 34 CFR section 668.22.
Repeat Finding: This is a repeat finding of 2023-004.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review, including reperformance of the calculations of the refund calculations to ensure calculations are being performed properly. In addition, we recommend that WCCC develop a process for ensuring calculations and subsequently, return of Title IV funding is done timely.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-003
Student Financial Aid Cluster
Special Tests and Provisions – Return of Title IV Funds
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs. Return of Title IV funds are required to be deposited or transferred into the Student Financial Aid Account or electronic fund transfers initiated to the Department of Education no later than 45 days after the date the institution determined that the student withdrew.
Condition: Our Return of Title IV Funds sample of 25 yielded three instances where the improper amount of funding was returned to the Department of Education. The calculation of the Return of Title IV Funds for the first student was based on a withdrawal date of February 5, 2024 when the actual withdrawal date was March 25, 2024. Based on the withdrawal date utilized in the calculation, WCCC returned a total of $1,023 of the subsidized loan award; however, based on the actual withdrawal date, the amount that should have been returned was $495.18, resulting in an overpayment of $527.82. The calculation of the Return of Title IV Funds for the second student did not include the unsubsidized loan in the calculation. The amount of Title IV Funds returned was $1,096, but had the unsubsidized loan been included in the calculation, only $747.18 should have been returned, resulting in an overpayment of $348.82. The calculation of the return of Title IV Funds for the third student, calculated a required return of Pell funding in the amount of $599.67. While the calculation of the return was correct, the amount calculated was not returned to the Department of Education, resulting in an underpayment of $599.67. Additionally, our Return of Title IV Funds sample of 25 yielded five instances in which the calculation was not performed within 45 days of the students’ withdrawal dates. As a result, $2,788.31 of funds were not returned timely to the Department of Education.
Cause: Controls were not in place to ensure that Return of Title IV Funds were performed accurately and timely.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC. Additionally, calculations were not performed timely. As a result, WCCC did not comply with requirements related to the calculation and timely return of Title IV Funds as outlined in 34 CFR section 668.22.
Repeat Finding: This is a repeat finding of 2023-004.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review, including reperformance of the calculations of the refund calculations to ensure calculations are being performed properly. In addition, we recommend that WCCC develop a process for ensuring calculations and subsequently, return of Title IV funding is done timely.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-003
Student Financial Aid Cluster
Special Tests and Provisions – Return of Title IV Funds
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs. Return of Title IV funds are required to be deposited or transferred into the Student Financial Aid Account or electronic fund transfers initiated to the Department of Education no later than 45 days after the date the institution determined that the student withdrew.
Condition: Our Return of Title IV Funds sample of 25 yielded three instances where the improper amount of funding was returned to the Department of Education. The calculation of the Return of Title IV Funds for the first student was based on a withdrawal date of February 5, 2024 when the actual withdrawal date was March 25, 2024. Based on the withdrawal date utilized in the calculation, WCCC returned a total of $1,023 of the subsidized loan award; however, based on the actual withdrawal date, the amount that should have been returned was $495.18, resulting in an overpayment of $527.82. The calculation of the Return of Title IV Funds for the second student did not include the unsubsidized loan in the calculation. The amount of Title IV Funds returned was $1,096, but had the unsubsidized loan been included in the calculation, only $747.18 should have been returned, resulting in an overpayment of $348.82. The calculation of the return of Title IV Funds for the third student, calculated a required return of Pell funding in the amount of $599.67. While the calculation of the return was correct, the amount calculated was not returned to the Department of Education, resulting in an underpayment of $599.67. Additionally, our Return of Title IV Funds sample of 25 yielded five instances in which the calculation was not performed within 45 days of the students’ withdrawal dates. As a result, $2,788.31 of funds were not returned timely to the Department of Education.
Cause: Controls were not in place to ensure that Return of Title IV Funds were performed accurately and timely.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC. Additionally, calculations were not performed timely. As a result, WCCC did not comply with requirements related to the calculation and timely return of Title IV Funds as outlined in 34 CFR section 668.22.
Repeat Finding: This is a repeat finding of 2023-004.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review, including reperformance of the calculations of the refund calculations to ensure calculations are being performed properly. In addition, we recommend that WCCC develop a process for ensuring calculations and subsequently, return of Title IV funding is done timely.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-001
Student Financial Aid Cluster
Cash Management
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster – (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have documented controls in place to ensure that drawdown requests for SFA Title IV funds do not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The documented controls in place should also ensure that any excess cash over the tolerable amount of one percent of the total amount of funds drawn by the institution in the prior award year and any amount remaining is returned to the Department of Education within seven days.
Condition: WCCC requests funds from the Department of Education under the Advance Payment Method. As permitted, WCCC elects to post Title IV disbursements prior to drawing funds. Although, WCCC draws funds after the SFA Title IV disbursements are posted, they are still responsible for ensuring funds were not drawn in excess of the tolerable amount and that any funds that were drawn in excess were returned within the required seven days. A documented reconciliation between the funds drawn and the funds disbursed could not be provided by WCCC. In addition, documented controls were not in place to ensure any excess cash over the tolerable amount of one percent and any remaining amounts were returned to the Department of Education within seven days. The results of our testing of Title IV draws did not identify instances in which draws exceeded disbursements by amounts in excess of the allowable one percent threshold.
Cause: Documented controls were not in place to ensure WCCC complied with the cash management requirements under the Advance Payment Method for SFA Title IV funds. WCCC implemented a new student financial aid module in March 2023 and documented procedures to address drawdown reconciliations are still being addressed.
Effect: Lack of documented controls of drawdown requests could result in excess funds being drawn and not returned to the Department of Education within the required timeframe.
Repeat Finding: This is not a repeat finding.
Questioned costs: None
Recommendation: We recommend that WCCC implement a clear, contemporaneously documented trail regarding the reconciliation process to ensure the SFA Title IV draws do not exceed SFA Title IV disbursements posted to student accounts. This documented process should include controls to ensure that any excess funds over the tolerable amount are returned to the Department of Education within the required seven days.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-001
Student Financial Aid Cluster
Cash Management
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster – (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have documented controls in place to ensure that drawdown requests for SFA Title IV funds do not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The documented controls in place should also ensure that any excess cash over the tolerable amount of one percent of the total amount of funds drawn by the institution in the prior award year and any amount remaining is returned to the Department of Education within seven days.
Condition: WCCC requests funds from the Department of Education under the Advance Payment Method. As permitted, WCCC elects to post Title IV disbursements prior to drawing funds. Although, WCCC draws funds after the SFA Title IV disbursements are posted, they are still responsible for ensuring funds were not drawn in excess of the tolerable amount and that any funds that were drawn in excess were returned within the required seven days. A documented reconciliation between the funds drawn and the funds disbursed could not be provided by WCCC. In addition, documented controls were not in place to ensure any excess cash over the tolerable amount of one percent and any remaining amounts were returned to the Department of Education within seven days. The results of our testing of Title IV draws did not identify instances in which draws exceeded disbursements by amounts in excess of the allowable one percent threshold.
Cause: Documented controls were not in place to ensure WCCC complied with the cash management requirements under the Advance Payment Method for SFA Title IV funds. WCCC implemented a new student financial aid module in March 2023 and documented procedures to address drawdown reconciliations are still being addressed.
Effect: Lack of documented controls of drawdown requests could result in excess funds being drawn and not returned to the Department of Education within the required timeframe.
Repeat Finding: This is not a repeat finding.
Questioned costs: None
Recommendation: We recommend that WCCC implement a clear, contemporaneously documented trail regarding the reconciliation process to ensure the SFA Title IV draws do not exceed SFA Title IV disbursements posted to student accounts. This documented process should include controls to ensure that any excess funds over the tolerable amount are returned to the Department of Education within the required seven days.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-001
Student Financial Aid Cluster
Cash Management
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster – (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have documented controls in place to ensure that drawdown requests for SFA Title IV funds do not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The documented controls in place should also ensure that any excess cash over the tolerable amount of one percent of the total amount of funds drawn by the institution in the prior award year and any amount remaining is returned to the Department of Education within seven days.
Condition: WCCC requests funds from the Department of Education under the Advance Payment Method. As permitted, WCCC elects to post Title IV disbursements prior to drawing funds. Although, WCCC draws funds after the SFA Title IV disbursements are posted, they are still responsible for ensuring funds were not drawn in excess of the tolerable amount and that any funds that were drawn in excess were returned within the required seven days. A documented reconciliation between the funds drawn and the funds disbursed could not be provided by WCCC. In addition, documented controls were not in place to ensure any excess cash over the tolerable amount of one percent and any remaining amounts were returned to the Department of Education within seven days. The results of our testing of Title IV draws did not identify instances in which draws exceeded disbursements by amounts in excess of the allowable one percent threshold.
Cause: Documented controls were not in place to ensure WCCC complied with the cash management requirements under the Advance Payment Method for SFA Title IV funds. WCCC implemented a new student financial aid module in March 2023 and documented procedures to address drawdown reconciliations are still being addressed.
Effect: Lack of documented controls of drawdown requests could result in excess funds being drawn and not returned to the Department of Education within the required timeframe.
Repeat Finding: This is not a repeat finding.
Questioned costs: None
Recommendation: We recommend that WCCC implement a clear, contemporaneously documented trail regarding the reconciliation process to ensure the SFA Title IV draws do not exceed SFA Title IV disbursements posted to student accounts. This documented process should include controls to ensure that any excess funds over the tolerable amount are returned to the Department of Education within the required seven days.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-001
Student Financial Aid Cluster
Cash Management
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster – (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have documented controls in place to ensure that drawdown requests for SFA Title IV funds do not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The documented controls in place should also ensure that any excess cash over the tolerable amount of one percent of the total amount of funds drawn by the institution in the prior award year and any amount remaining is returned to the Department of Education within seven days.
Condition: WCCC requests funds from the Department of Education under the Advance Payment Method. As permitted, WCCC elects to post Title IV disbursements prior to drawing funds. Although, WCCC draws funds after the SFA Title IV disbursements are posted, they are still responsible for ensuring funds were not drawn in excess of the tolerable amount and that any funds that were drawn in excess were returned within the required seven days. A documented reconciliation between the funds drawn and the funds disbursed could not be provided by WCCC. In addition, documented controls were not in place to ensure any excess cash over the tolerable amount of one percent and any remaining amounts were returned to the Department of Education within seven days. The results of our testing of Title IV draws did not identify instances in which draws exceeded disbursements by amounts in excess of the allowable one percent threshold.
Cause: Documented controls were not in place to ensure WCCC complied with the cash management requirements under the Advance Payment Method for SFA Title IV funds. WCCC implemented a new student financial aid module in March 2023 and documented procedures to address drawdown reconciliations are still being addressed.
Effect: Lack of documented controls of drawdown requests could result in excess funds being drawn and not returned to the Department of Education within the required timeframe.
Repeat Finding: This is not a repeat finding.
Questioned costs: None
Recommendation: We recommend that WCCC implement a clear, contemporaneously documented trail regarding the reconciliation process to ensure the SFA Title IV draws do not exceed SFA Title IV disbursements posted to student accounts. This documented process should include controls to ensure that any excess funds over the tolerable amount are returned to the Department of Education within the required seven days.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-002
Student Financial Aid Cluster
Allowable Costs and Allowable Activities and Eligibility
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need. These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts.
Condition: Our financial aid sample of 40 items tested yielded 29 students who received Pell Grant Funding. Of the 29 students who received Pell Grant funding, we noted 1 instance where the student received the incorrect amount of Pell funding. Based on the students expected family contribution, the student should have received $925 in Pell funding; however, they only received $631 in Pell funding, resulting in an underpayment of Pell funding of $294. Of the 40 students selected for testing, WCCC was also not able to provide documentation of the calculations performed to determine each student’s cost of attendance for all 40 students. Additionally, the cost of attendance amounts within the newly implemented enterprise-wide system student financial aid module could not be relied upon to reperform calculations to determine proper award amounts. Cost of attendance calculations were done by the auditors for the 40 individuals selected for testing to determine if the award amounts were appropriate.
Cause: Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to. As a result of system changes, cost of attendance calculations within the system could not be relied upon and WCCC did not maintain documentation for the manual cost of attendance calculations performed at the time students were awarded financial assistance.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for.
Repeat Finding: This is a repeat finding of 2023-003.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant fund and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-002
Student Financial Aid Cluster
Allowable Costs and Allowable Activities and Eligibility
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need. These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts.
Condition: Our financial aid sample of 40 items tested yielded 29 students who received Pell Grant Funding. Of the 29 students who received Pell Grant funding, we noted 1 instance where the student received the incorrect amount of Pell funding. Based on the students expected family contribution, the student should have received $925 in Pell funding; however, they only received $631 in Pell funding, resulting in an underpayment of Pell funding of $294. Of the 40 students selected for testing, WCCC was also not able to provide documentation of the calculations performed to determine each student’s cost of attendance for all 40 students. Additionally, the cost of attendance amounts within the newly implemented enterprise-wide system student financial aid module could not be relied upon to reperform calculations to determine proper award amounts. Cost of attendance calculations were done by the auditors for the 40 individuals selected for testing to determine if the award amounts were appropriate.
Cause: Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to. As a result of system changes, cost of attendance calculations within the system could not be relied upon and WCCC did not maintain documentation for the manual cost of attendance calculations performed at the time students were awarded financial assistance.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for.
Repeat Finding: This is a repeat finding of 2023-003.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant fund and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-002
Student Financial Aid Cluster
Allowable Costs and Allowable Activities and Eligibility
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need. These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts.
Condition: Our financial aid sample of 40 items tested yielded 29 students who received Pell Grant Funding. Of the 29 students who received Pell Grant funding, we noted 1 instance where the student received the incorrect amount of Pell funding. Based on the students expected family contribution, the student should have received $925 in Pell funding; however, they only received $631 in Pell funding, resulting in an underpayment of Pell funding of $294. Of the 40 students selected for testing, WCCC was also not able to provide documentation of the calculations performed to determine each student’s cost of attendance for all 40 students. Additionally, the cost of attendance amounts within the newly implemented enterprise-wide system student financial aid module could not be relied upon to reperform calculations to determine proper award amounts. Cost of attendance calculations were done by the auditors for the 40 individuals selected for testing to determine if the award amounts were appropriate.
Cause: Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to. As a result of system changes, cost of attendance calculations within the system could not be relied upon and WCCC did not maintain documentation for the manual cost of attendance calculations performed at the time students were awarded financial assistance.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for.
Repeat Finding: This is a repeat finding of 2023-003.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant fund and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-002
Student Financial Aid Cluster
Allowable Costs and Allowable Activities and Eligibility
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need. These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts.
Condition: Our financial aid sample of 40 items tested yielded 29 students who received Pell Grant Funding. Of the 29 students who received Pell Grant funding, we noted 1 instance where the student received the incorrect amount of Pell funding. Based on the students expected family contribution, the student should have received $925 in Pell funding; however, they only received $631 in Pell funding, resulting in an underpayment of Pell funding of $294. Of the 40 students selected for testing, WCCC was also not able to provide documentation of the calculations performed to determine each student’s cost of attendance for all 40 students. Additionally, the cost of attendance amounts within the newly implemented enterprise-wide system student financial aid module could not be relied upon to reperform calculations to determine proper award amounts. Cost of attendance calculations were done by the auditors for the 40 individuals selected for testing to determine if the award amounts were appropriate.
Cause: Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to. As a result of system changes, cost of attendance calculations within the system could not be relied upon and WCCC did not maintain documentation for the manual cost of attendance calculations performed at the time students were awarded financial assistance.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for.
Repeat Finding: This is a repeat finding of 2023-003.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant fund and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-003
Student Financial Aid Cluster
Special Tests and Provisions – Return of Title IV Funds
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs. Return of Title IV funds are required to be deposited or transferred into the Student Financial Aid Account or electronic fund transfers initiated to the Department of Education no later than 45 days after the date the institution determined that the student withdrew.
Condition: Our Return of Title IV Funds sample of 25 yielded three instances where the improper amount of funding was returned to the Department of Education. The calculation of the Return of Title IV Funds for the first student was based on a withdrawal date of February 5, 2024 when the actual withdrawal date was March 25, 2024. Based on the withdrawal date utilized in the calculation, WCCC returned a total of $1,023 of the subsidized loan award; however, based on the actual withdrawal date, the amount that should have been returned was $495.18, resulting in an overpayment of $527.82. The calculation of the Return of Title IV Funds for the second student did not include the unsubsidized loan in the calculation. The amount of Title IV Funds returned was $1,096, but had the unsubsidized loan been included in the calculation, only $747.18 should have been returned, resulting in an overpayment of $348.82. The calculation of the return of Title IV Funds for the third student, calculated a required return of Pell funding in the amount of $599.67. While the calculation of the return was correct, the amount calculated was not returned to the Department of Education, resulting in an underpayment of $599.67. Additionally, our Return of Title IV Funds sample of 25 yielded five instances in which the calculation was not performed within 45 days of the students’ withdrawal dates. As a result, $2,788.31 of funds were not returned timely to the Department of Education.
Cause: Controls were not in place to ensure that Return of Title IV Funds were performed accurately and timely.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC. Additionally, calculations were not performed timely. As a result, WCCC did not comply with requirements related to the calculation and timely return of Title IV Funds as outlined in 34 CFR section 668.22.
Repeat Finding: This is a repeat finding of 2023-004.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review, including reperformance of the calculations of the refund calculations to ensure calculations are being performed properly. In addition, we recommend that WCCC develop a process for ensuring calculations and subsequently, return of Title IV funding is done timely.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-003
Student Financial Aid Cluster
Special Tests and Provisions – Return of Title IV Funds
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs. Return of Title IV funds are required to be deposited or transferred into the Student Financial Aid Account or electronic fund transfers initiated to the Department of Education no later than 45 days after the date the institution determined that the student withdrew.
Condition: Our Return of Title IV Funds sample of 25 yielded three instances where the improper amount of funding was returned to the Department of Education. The calculation of the Return of Title IV Funds for the first student was based on a withdrawal date of February 5, 2024 when the actual withdrawal date was March 25, 2024. Based on the withdrawal date utilized in the calculation, WCCC returned a total of $1,023 of the subsidized loan award; however, based on the actual withdrawal date, the amount that should have been returned was $495.18, resulting in an overpayment of $527.82. The calculation of the Return of Title IV Funds for the second student did not include the unsubsidized loan in the calculation. The amount of Title IV Funds returned was $1,096, but had the unsubsidized loan been included in the calculation, only $747.18 should have been returned, resulting in an overpayment of $348.82. The calculation of the return of Title IV Funds for the third student, calculated a required return of Pell funding in the amount of $599.67. While the calculation of the return was correct, the amount calculated was not returned to the Department of Education, resulting in an underpayment of $599.67. Additionally, our Return of Title IV Funds sample of 25 yielded five instances in which the calculation was not performed within 45 days of the students’ withdrawal dates. As a result, $2,788.31 of funds were not returned timely to the Department of Education.
Cause: Controls were not in place to ensure that Return of Title IV Funds were performed accurately and timely.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC. Additionally, calculations were not performed timely. As a result, WCCC did not comply with requirements related to the calculation and timely return of Title IV Funds as outlined in 34 CFR section 668.22.
Repeat Finding: This is a repeat finding of 2023-004.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review, including reperformance of the calculations of the refund calculations to ensure calculations are being performed properly. In addition, we recommend that WCCC develop a process for ensuring calculations and subsequently, return of Title IV funding is done timely.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-003
Student Financial Aid Cluster
Special Tests and Provisions – Return of Title IV Funds
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs. Return of Title IV funds are required to be deposited or transferred into the Student Financial Aid Account or electronic fund transfers initiated to the Department of Education no later than 45 days after the date the institution determined that the student withdrew.
Condition: Our Return of Title IV Funds sample of 25 yielded three instances where the improper amount of funding was returned to the Department of Education. The calculation of the Return of Title IV Funds for the first student was based on a withdrawal date of February 5, 2024 when the actual withdrawal date was March 25, 2024. Based on the withdrawal date utilized in the calculation, WCCC returned a total of $1,023 of the subsidized loan award; however, based on the actual withdrawal date, the amount that should have been returned was $495.18, resulting in an overpayment of $527.82. The calculation of the Return of Title IV Funds for the second student did not include the unsubsidized loan in the calculation. The amount of Title IV Funds returned was $1,096, but had the unsubsidized loan been included in the calculation, only $747.18 should have been returned, resulting in an overpayment of $348.82. The calculation of the return of Title IV Funds for the third student, calculated a required return of Pell funding in the amount of $599.67. While the calculation of the return was correct, the amount calculated was not returned to the Department of Education, resulting in an underpayment of $599.67. Additionally, our Return of Title IV Funds sample of 25 yielded five instances in which the calculation was not performed within 45 days of the students’ withdrawal dates. As a result, $2,788.31 of funds were not returned timely to the Department of Education.
Cause: Controls were not in place to ensure that Return of Title IV Funds were performed accurately and timely.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC. Additionally, calculations were not performed timely. As a result, WCCC did not comply with requirements related to the calculation and timely return of Title IV Funds as outlined in 34 CFR section 668.22.
Repeat Finding: This is a repeat finding of 2023-004.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review, including reperformance of the calculations of the refund calculations to ensure calculations are being performed properly. In addition, we recommend that WCCC develop a process for ensuring calculations and subsequently, return of Title IV funding is done timely.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.
Finding 2024-003
Student Financial Aid Cluster
Special Tests and Provisions – Return of Title IV Funds
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268)
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs. Return of Title IV funds are required to be deposited or transferred into the Student Financial Aid Account or electronic fund transfers initiated to the Department of Education no later than 45 days after the date the institution determined that the student withdrew.
Condition: Our Return of Title IV Funds sample of 25 yielded three instances where the improper amount of funding was returned to the Department of Education. The calculation of the Return of Title IV Funds for the first student was based on a withdrawal date of February 5, 2024 when the actual withdrawal date was March 25, 2024. Based on the withdrawal date utilized in the calculation, WCCC returned a total of $1,023 of the subsidized loan award; however, based on the actual withdrawal date, the amount that should have been returned was $495.18, resulting in an overpayment of $527.82. The calculation of the Return of Title IV Funds for the second student did not include the unsubsidized loan in the calculation. The amount of Title IV Funds returned was $1,096, but had the unsubsidized loan been included in the calculation, only $747.18 should have been returned, resulting in an overpayment of $348.82. The calculation of the return of Title IV Funds for the third student, calculated a required return of Pell funding in the amount of $599.67. While the calculation of the return was correct, the amount calculated was not returned to the Department of Education, resulting in an underpayment of $599.67. Additionally, our Return of Title IV Funds sample of 25 yielded five instances in which the calculation was not performed within 45 days of the students’ withdrawal dates. As a result, $2,788.31 of funds were not returned timely to the Department of Education.
Cause: Controls were not in place to ensure that Return of Title IV Funds were performed accurately and timely.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC. Additionally, calculations were not performed timely. As a result, WCCC did not comply with requirements related to the calculation and timely return of Title IV Funds as outlined in 34 CFR section 668.22.
Repeat Finding: This is a repeat finding of 2023-004.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review, including reperformance of the calculations of the refund calculations to ensure calculations are being performed properly. In addition, we recommend that WCCC develop a process for ensuring calculations and subsequently, return of Title IV funding is done timely.
View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.