Finding 2024-001 - Significant Deficiency - Return of Title IV
Federal Program - Federal Pell Grant Program, Federal Direct Student Loan Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN Number - 84.063, 84.268
Federal Award Year - May 31, 2024
Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date.
Condition/Context: The amount of Title IV aid to be refunded was not properly calculated for three out of three students tested with Return of Title IV calculations which resulted in the College returning more Title IV aid than necessary for two students, and less Title IV aid than necessary for one student.
The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: The College did not properly review the calculations completed when determining the number of days in a term, as the total amount of days in their fall and spring breaks were not excluded. This resulted in the incorrect unearned aid percentage to be used in all Fall 2023 and Spring 2024 refund calculations. In addition, graduate students had their start dates incorrectly listed as there were different start dates for different graduate programs. This also affected the refund calculations for those students and contributed further to the unearned aid percentage being incorrect. As soon as the improper calculations were brought to the attention of the College, all students for whom an R2T4 calculation was performed in Fall 2023 and Spring 2024 had their R2T4s recalculated.
Effect: The College returned more aid than necessary for two students based on the students’ percentage of completion in the Fall 2023 semester, and did not return enough aid for one student based on the student's percentage of completion in the spring 2024 semester.
Questioned Costs: The College returned $288 more in Federal Direct Loans and $0 more in Federal Pell Grants than necessary based on the inaccurate R2T4 calculations in the Fall 2023 semester. For the Spring 2024 semester, the College returned $297 less in Federal Direct Loans and $0 less in Federal Pell grants compared to what was necessary, based on the inaccurate R2T4 calculations that were completed for that semester.
Recommendation: The College should reevaluate the process around completing R2T4 calculations to ensure only the amount of aid earned by a student gets disbursed. In addition, this process should involve a secondary level of review to ensure the days completed and total days in the semester are accurate based on the College’s academic calendars.
View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring.
Finding 2024-001 - Significant Deficiency - Return of Title IV
Federal Program - Federal Pell Grant Program, Federal Direct Student Loan Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN Number - 84.063, 84.268
Federal Award Year - May 31, 2024
Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date.
Condition/Context: The amount of Title IV aid to be refunded was not properly calculated for three out of three students tested with Return of Title IV calculations which resulted in the College returning more Title IV aid than necessary for two students, and less Title IV aid than necessary for one student.
The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: The College did not properly review the calculations completed when determining the number of days in a term, as the total amount of days in their fall and spring breaks were not excluded. This resulted in the incorrect unearned aid percentage to be used in all Fall 2023 and Spring 2024 refund calculations. In addition, graduate students had their start dates incorrectly listed as there were different start dates for different graduate programs. This also affected the refund calculations for those students and contributed further to the unearned aid percentage being incorrect. As soon as the improper calculations were brought to the attention of the College, all students for whom an R2T4 calculation was performed in Fall 2023 and Spring 2024 had their R2T4s recalculated.
Effect: The College returned more aid than necessary for two students based on the students’ percentage of completion in the Fall 2023 semester, and did not return enough aid for one student based on the student's percentage of completion in the spring 2024 semester.
Questioned Costs: The College returned $288 more in Federal Direct Loans and $0 more in Federal Pell Grants than necessary based on the inaccurate R2T4 calculations in the Fall 2023 semester. For the Spring 2024 semester, the College returned $297 less in Federal Direct Loans and $0 less in Federal Pell grants compared to what was necessary, based on the inaccurate R2T4 calculations that were completed for that semester.
Recommendation: The College should reevaluate the process around completing R2T4 calculations to ensure only the amount of aid earned by a student gets disbursed. In addition, this process should involve a secondary level of review to ensure the days completed and total days in the semester are accurate based on the College’s academic calendars.
View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring.
Finding 2024-001 - Significant Deficiency - Return of Title IV
Federal Program - Federal Pell Grant Program, Federal Direct Student Loan Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN Number - 84.063, 84.268
Federal Award Year - May 31, 2024
Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date.
Condition/Context: The amount of Title IV aid to be refunded was not properly calculated for three out of three students tested with Return of Title IV calculations which resulted in the College returning more Title IV aid than necessary for two students, and less Title IV aid than necessary for one student.
The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: The College did not properly review the calculations completed when determining the number of days in a term, as the total amount of days in their fall and spring breaks were not excluded. This resulted in the incorrect unearned aid percentage to be used in all Fall 2023 and Spring 2024 refund calculations. In addition, graduate students had their start dates incorrectly listed as there were different start dates for different graduate programs. This also affected the refund calculations for those students and contributed further to the unearned aid percentage being incorrect. As soon as the improper calculations were brought to the attention of the College, all students for whom an R2T4 calculation was performed in Fall 2023 and Spring 2024 had their R2T4s recalculated.
Effect: The College returned more aid than necessary for two students based on the students’ percentage of completion in the Fall 2023 semester, and did not return enough aid for one student based on the student's percentage of completion in the spring 2024 semester.
Questioned Costs: The College returned $288 more in Federal Direct Loans and $0 more in Federal Pell Grants than necessary based on the inaccurate R2T4 calculations in the Fall 2023 semester. For the Spring 2024 semester, the College returned $297 less in Federal Direct Loans and $0 less in Federal Pell grants compared to what was necessary, based on the inaccurate R2T4 calculations that were completed for that semester.
Recommendation: The College should reevaluate the process around completing R2T4 calculations to ensure only the amount of aid earned by a student gets disbursed. In addition, this process should involve a secondary level of review to ensure the days completed and total days in the semester are accurate based on the College’s academic calendars.
View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring.
Finding 2024-001 - Significant Deficiency - Return of Title IV
Federal Program - Federal Pell Grant Program, Federal Direct Student Loan Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN Number - 84.063, 84.268
Federal Award Year - May 31, 2024
Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date.
Condition/Context: The amount of Title IV aid to be refunded was not properly calculated for three out of three students tested with Return of Title IV calculations which resulted in the College returning more Title IV aid than necessary for two students, and less Title IV aid than necessary for one student.
The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: The College did not properly review the calculations completed when determining the number of days in a term, as the total amount of days in their fall and spring breaks were not excluded. This resulted in the incorrect unearned aid percentage to be used in all Fall 2023 and Spring 2024 refund calculations. In addition, graduate students had their start dates incorrectly listed as there were different start dates for different graduate programs. This also affected the refund calculations for those students and contributed further to the unearned aid percentage being incorrect. As soon as the improper calculations were brought to the attention of the College, all students for whom an R2T4 calculation was performed in Fall 2023 and Spring 2024 had their R2T4s recalculated.
Effect: The College returned more aid than necessary for two students based on the students’ percentage of completion in the Fall 2023 semester, and did not return enough aid for one student based on the student's percentage of completion in the spring 2024 semester.
Questioned Costs: The College returned $288 more in Federal Direct Loans and $0 more in Federal Pell Grants than necessary based on the inaccurate R2T4 calculations in the Fall 2023 semester. For the Spring 2024 semester, the College returned $297 less in Federal Direct Loans and $0 less in Federal Pell grants compared to what was necessary, based on the inaccurate R2T4 calculations that were completed for that semester.
Recommendation: The College should reevaluate the process around completing R2T4 calculations to ensure only the amount of aid earned by a student gets disbursed. In addition, this process should involve a secondary level of review to ensure the days completed and total days in the semester are accurate based on the College’s academic calendars.
View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring.