Audit 346554

Finding 2024-001 – Significant Deficiency: Special Tests And Provisions – Return Of Title IV Funds – Compliance and Control Finding ALN 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible under 34 CFR 668.22(g) as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as defined in 34 CFR 668.22(l)(3). Condition: The University did not return Title IV funds within the 45-day time period for 1 student tested in our sample population. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University’s controls did not prevent the errors noted during the return of Title IV funds. Questioned Costs: $1,559 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: The University provided a listing of all students that withdrew during the academic period, which totaled 68 students. In a statistically valid sample of 7 students that withdrew, the University did not return Title IV funds during the required time period for 1 student tested. Identification As A Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: During the 2023-2024 academic year, Financial Aid employees attended a training over return of Title IV funds, in which they became aware that students who received all incomplete ‘I’ grades for a term had 30 days following that term to complete the courses. If those courses remained incomplete at the end of the 30 days, they should be treated the same as students with all F grades. At that time, financial aid must determine if they are required to complete a return of funds for that student. After the training, funds were returned to Title IV for students who received all ‘I’ grades for the fall 2023 trimester. Total questioned costs related to this amounted to $1,559. The University remains aware of the rules surrounding return of funds for students with all ‘I’ grades and will continue to attend Student Financial Aid trainings.

Finding 2024-001 – Significant Deficiency: Special Tests And Provisions – Return Of Title IV Funds – Compliance and Control Finding ALN 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible under 34 CFR 668.22(g) as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as defined in 34 CFR 668.22(l)(3). Condition: The University did not return Title IV funds within the 45-day time period for 1 student tested in our sample population. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University’s controls did not prevent the errors noted during the return of Title IV funds. Questioned Costs: $1,559 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: The University provided a listing of all students that withdrew during the academic period, which totaled 68 students. In a statistically valid sample of 7 students that withdrew, the University did not return Title IV funds during the required time period for 1 student tested. Identification As A Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: During the 2023-2024 academic year, Financial Aid employees attended a training over return of Title IV funds, in which they became aware that students who received all incomplete ‘I’ grades for a term had 30 days following that term to complete the courses. If those courses remained incomplete at the end of the 30 days, they should be treated the same as students with all F grades. At that time, financial aid must determine if they are required to complete a return of funds for that student. After the training, funds were returned to Title IV for students who received all ‘I’ grades for the fall 2023 trimester. Total questioned costs related to this amounted to $1,559. The University remains aware of the rules surrounding return of funds for students with all ‘I’ grades and will continue to attend Student Financial Aid trainings.