Audit 390704

Finding Reference: 2025-001 Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Compliance Requirements: Return of Title IV Funds Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria: Under 34 CFR 668.21(b), institutions are required to return Title IV funds within 30 days of determining that a student never began attendance. Additionally, 34 CFR 668.173(b) requires institutions to return Title IV funds within the timeframes established under the federal cash management regulations, generally within 45 days of the date the institution determines a return is necessary. Institutions must also maintain internal controls sufficient to ensure accurate calculation and timely processing of required returns. Statement of Condition: The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30 day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Statement of Cause: The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30 day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Possible Asserted Effect: Failure to return Title IV funds within required timeframes places federal funds at risk and results in noncompliance with Title IV regulations. Continued deficiencies may expose the College to potential liabilities for improperly retained funds or increased oversight such as heightened cash monitoring. Questioned Costs: $10,349 Context: A sample of 50 students were selected for return to Title IV testing and 5 students were identified with untimely refunds. The sample was not intended to be, and was not, a statistically valid sample. The College has already returned these funds to the U.S. Department of Education. Repeat Finding: No Recommendation: The College should strengthen its internal controls and monitoring procedures to ensure compliance with federal return of funds requirements. This should include timely verification that calculated refund amounts match what is actually returned, improved review processes to confirm that students who never attended are identified promptly, and training for relevant staff to ensure consistent understanding and execution of federal aid return requirements. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges and accepts this finding. Processes that will mitigate this concern in the future had already been underway in the 2025-2026 aid year, and those practices, in addition to other steps we will take as part of the Corrective Action Plan, should eliminate future findings of this nature.