2024-002 – Return of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. Funds were returned more than 45 days after the date of determination for all students that required refunds. Cause: Controls are not functioning properly to ensure timely return. Effect: Funds were not timely returned to students or the Department of Education as required. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination.Action Taken: Due to a significant change/shortage in staff some R2T4’s were not calculated in a timely manner, however we are currently running the report biweekly avoiding delays in the return of Title IV funds. Reminders are placed on calendars. Attendance policy is undergoing a revision to allow for more consistent totals when calculating the number of days. In addition the process has been automated in Financial Aid software so it will no longer be a manual calculation. Responsible Party and contact information: Lynda Swanson, Asst. Director of Financial Aid, Valerie Souza, FA Business Systems Analyst, and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Trimester reconciliation-completion date-end of fiscal year.
2024-003 – Incorrect Calculation of Title IV Refunds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period (34 CFR Section 668.22(f)(2)(i)). For a student that ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is the date that the student provided official notification to the institution, in writing or really, of his or her intent to withdraw (CFR Section 668.22(c)(1)(ii)). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. From these calculations we noted the following: Spring break of nine days was deducted incorrectly as seven days instead of nine for the three students who withdrew during spring semester. One student’s date of withdrawal was incorrect on the refund calculation. Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the conditions listed above: The University’s spring break was for the period of February 24, 2024 through March 3, 2024, a nine consecutive calendar day period. However, the University did not include the first two weekend days and calculated the break as seven days instead of nine. Due to this error, the correct number of days for the break was not deducted from the total number of calendar days properly for purposes of calculating refunds. One student’s withdrawal date was entered incorrectly in the R2T4 calculation. Effect: Refunds were calculated incorrectly for three of the four students that required refund calculations resulting in an incorrect amount of funds returned to the student and the Department of Education. Recommendation: We recommend procedures are put in place to ensure accuracy of R2T4 calculations. Action Taken: The Director of Financial Aid as well as the Data Analyst who is responsible for calculating the Return of Title 4 refunds have retaken the training module on calculating R2T4’s and counting days. This process was done manually allowing for marginal errors. Currently we have moved the process to be calculated automatically within our financial aid system which will reduce the margin of errors immensely and dates would be calculated correctly. This too will be affected by the revision of the new attendance policy. Responsible Party and contact information: Valerie Souza, FA Business Systems Analyst and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: The process has been instituted and has gone into effect immediately.
2024-001 – Preparation of the Schedule of Expenditures of Federal Awards (SEFA) (Significant Deficiency) Criteria: According to 2 CFR 200.210(b), a recipient of Federal awards is required to prepare a SEFA for the period covered by the entity’s financial statement which must include the total Federal awards expended. In addition, 2 CFR 200.303 requires non-Federal entities to, among other things, establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Effective internal controls should include procedures to ensure expenditures are properly reported on the SEFA. In addition to providing an accurate SEFA, an organization must also be able to demonstrate that it has a system of internal control that supports the preparation of the SEFA. Condition: The University did not have an adequate process in place to prepare and review its SEFA. Cause: The University’s internal control process for preparing the SEFA did not include review and approval of the SEFA prior to providing it to the auditor. Effect: Failure to accurately report federal expenditures on the SEFA could result in noncompliance with federal regulations. Recommendation: We recommend the University establish, document, and maintain effective internal controls over the preparation of the SEFA. At a minimum, an organization should be able to show documentation that the SEFA was reviewed and approved by an individual who was not directly involved with the initial preparation of the SEFA. The review process should include checking both the reported expenditures of federal awards and the assistance listing numbers reported for each grant program. Action Taken: Management has put in place the following procedures: We will establish, document and maintain effective internal control over Federal awards by performing reconciliation of federal funds at the end of each trimester. The account reconciled will be listed on the SEFA. The Director of Financial Aid will be responsible for preparing the SEFA. It will be reviewed and re-reconciled by the Business Systems Analyst and the FA Asst. Director. Reports used to reconcile come from our Sonis system and are the Award Summary Detail and the Charges and Credits reports. Responsible Party and contact information: Valerie Souza, FA Business Systems Analyst and Lynda Swanson, Asst. Director of Financial Aid. Expected Date of Correction: At the end of each trimester. Full completion of processes will be at the end of our fiscal year/calendar year when audit preparation begins.
2024-004 – Disbursing Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Except for paying a student under the Federal Work Study program or unless 34 CFR 685.303(d)(4)(i) applies, an institution must disburse during the current payment period the amount of Title IV, HEA program funds that a student enrolled at the institution is eligible to receive for that payment period. (34 CFR 668.164 (b)(1). Condition: From a population of 679 students that received the Pell grant, we tested 24 students and noted that two students did not receive the Pell awards for which they were eligible, and one student received an incorrect Pell award. Cause: Controls to ensure accurate disbursements to students are not functioning properly. Effect: Two students did not receive Pell awards they were eligible for during the payment period and one student received more Pell funds than they were entitled to. Recommendation: We recommend that procedures are put in place to ensure timely and accurate payment of Title VI awards. Action Taken: Shortages in staffing did not allow for double checking student enrollment post census. To correct this situation, we have added an additional counselor. We are working with a consultant to automate manual processes to free up more counselor time. Responsible Party and contact information: Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Beginning with the summer 2025 trimester and ending at the end of the fiscal year.
2024-002 – Return of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. Funds were returned more than 45 days after the date of determination for all students that required refunds. Cause: Controls are not functioning properly to ensure timely return. Effect: Funds were not timely returned to students or the Department of Education as required. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination.Action Taken: Due to a significant change/shortage in staff some R2T4’s were not calculated in a timely manner, however we are currently running the report biweekly avoiding delays in the return of Title IV funds. Reminders are placed on calendars. Attendance policy is undergoing a revision to allow for more consistent totals when calculating the number of days. In addition the process has been automated in Financial Aid software so it will no longer be a manual calculation. Responsible Party and contact information: Lynda Swanson, Asst. Director of Financial Aid, Valerie Souza, FA Business Systems Analyst, and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Trimester reconciliation-completion date-end of fiscal year.
2024-003 – Incorrect Calculation of Title IV Refunds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period (34 CFR Section 668.22(f)(2)(i)). For a student that ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is the date that the student provided official notification to the institution, in writing or really, of his or her intent to withdraw (CFR Section 668.22(c)(1)(ii)). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. From these calculations we noted the following: Spring break of nine days was deducted incorrectly as seven days instead of nine for the three students who withdrew during spring semester. One student’s date of withdrawal was incorrect on the refund calculation. Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the conditions listed above: The University’s spring break was for the period of February 24, 2024 through March 3, 2024, a nine consecutive calendar day period. However, the University did not include the first two weekend days and calculated the break as seven days instead of nine. Due to this error, the correct number of days for the break was not deducted from the total number of calendar days properly for purposes of calculating refunds. One student’s withdrawal date was entered incorrectly in the R2T4 calculation. Effect: Refunds were calculated incorrectly for three of the four students that required refund calculations resulting in an incorrect amount of funds returned to the student and the Department of Education. Recommendation: We recommend procedures are put in place to ensure accuracy of R2T4 calculations. Action Taken: The Director of Financial Aid as well as the Data Analyst who is responsible for calculating the Return of Title 4 refunds have retaken the training module on calculating R2T4’s and counting days. This process was done manually allowing for marginal errors. Currently we have moved the process to be calculated automatically within our financial aid system which will reduce the margin of errors immensely and dates would be calculated correctly. This too will be affected by the revision of the new attendance policy. Responsible Party and contact information: Valerie Souza, FA Business Systems Analyst and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: The process has been instituted and has gone into effect immediately.
2024-001 – Preparation of the Schedule of Expenditures of Federal Awards (SEFA) (Significant Deficiency) Criteria: According to 2 CFR 200.210(b), a recipient of Federal awards is required to prepare a SEFA for the period covered by the entity’s financial statement which must include the total Federal awards expended. In addition, 2 CFR 200.303 requires non-Federal entities to, among other things, establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Effective internal controls should include procedures to ensure expenditures are properly reported on the SEFA. In addition to providing an accurate SEFA, an organization must also be able to demonstrate that it has a system of internal control that supports the preparation of the SEFA. Condition: The University did not have an adequate process in place to prepare and review its SEFA. Cause: The University’s internal control process for preparing the SEFA did not include review and approval of the SEFA prior to providing it to the auditor. Effect: Failure to accurately report federal expenditures on the SEFA could result in noncompliance with federal regulations. Recommendation: We recommend the University establish, document, and maintain effective internal controls over the preparation of the SEFA. At a minimum, an organization should be able to show documentation that the SEFA was reviewed and approved by an individual who was not directly involved with the initial preparation of the SEFA. The review process should include checking both the reported expenditures of federal awards and the assistance listing numbers reported for each grant program. Action Taken: Management has put in place the following procedures: We will establish, document and maintain effective internal control over Federal awards by performing reconciliation of federal funds at the end of each trimester. The account reconciled will be listed on the SEFA. The Director of Financial Aid will be responsible for preparing the SEFA. It will be reviewed and re-reconciled by the Business Systems Analyst and the FA Asst. Director. Reports used to reconcile come from our Sonis system and are the Award Summary Detail and the Charges and Credits reports. Responsible Party and contact information: Valerie Souza, FA Business Systems Analyst and Lynda Swanson, Asst. Director of Financial Aid. Expected Date of Correction: At the end of each trimester. Full completion of processes will be at the end of our fiscal year/calendar year when audit preparation begins.
2024-004 – Disbursing Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Except for paying a student under the Federal Work Study program or unless 34 CFR 685.303(d)(4)(i) applies, an institution must disburse during the current payment period the amount of Title IV, HEA program funds that a student enrolled at the institution is eligible to receive for that payment period. (34 CFR 668.164 (b)(1). Condition: From a population of 679 students that received the Pell grant, we tested 24 students and noted that two students did not receive the Pell awards for which they were eligible, and one student received an incorrect Pell award. Cause: Controls to ensure accurate disbursements to students are not functioning properly. Effect: Two students did not receive Pell awards they were eligible for during the payment period and one student received more Pell funds than they were entitled to. Recommendation: We recommend that procedures are put in place to ensure timely and accurate payment of Title VI awards. Action Taken: Shortages in staffing did not allow for double checking student enrollment post census. To correct this situation, we have added an additional counselor. We are working with a consultant to automate manual processes to free up more counselor time. Responsible Party and contact information: Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Beginning with the summer 2025 trimester and ending at the end of the fiscal year.