Audit 398469

Condition: For one student included in the audit sample, the institution did not complete the Return of Title IV Funds (R2T4) calculation or return unearned Federal Pell Grant funds within required timeframes. Specifically, the date of the institution’s determination that the student withdrew was April 2025. The required R2T4 calculation was not completed until February 2026, approximately ten months after the determination date. As a result of the delayed R2T4 calculation, the institution did not initiate the required cash return of unearned Federal Pell Grant funds within 45 days of the date of determination. Criteria : Federal regulations require institutions to determine and calculate the amount of Title IV aid earned when a student withdraws by performing a Return of Title IV Funds (R2T4) calculation based on the date of the institution’s determination that the student withdrew; and return any unearned Title IV funds within 45 days of that determination date. Cause: The institution did not have effective controls in place to ensure that R2T4 calculations were completed promptly after a student’s withdrawal was determined; and Pell Grant refunds identified through the R2T4 process were returned through G5 within required timeframes. Effect: Failure to complete the R2T4 calculation timely resulted in an untimely return of unearned Pell Grant funds, constituting noncompliance with Title IV cash management and R2T4 regulations. Repeat Finding: No. Recommendation: We recommend that the University establish procedures requiring timely identification of withdrawn students and completion of R2T4 calculations as required by federal regulations and perform periodic internal reviews of withdrawal and refund activity to ensure ongoing compliance. Views of Responsible Officials: The finding was in the No Passing Grade selection. Due to the way the institution tracks attendance, the student was listed as having earned an F instead of being administratively withdrawn. The institution will now start using a new report. This report will track: o Any student with a no passing grade o Any student in this category who received financial aid. IT has developed this report and the report is identified as the No passing Grades report. This will allow the institution to review and determine if the student needs to be considered as an unofficial withdrawal and whether or not an R2T4 is needed. The FA Business Systems analyst will run this report at the end of each term when grades have been issued. The institution will also meet with the Faculty Senate to put a process in place which will determine whether the student who earned a no passing grade participated in the course or should have been administratively withdrawn at the time grades are issued. This will help the institution to determine if an R2T4 calculation was needed and allow for a timely return of funds.

Condition: The Institution prepared and submitted the FISAP without evidence of an independent, documented management review prior to submission. Criteria: Institutions participating in the Campus-Based programs are required to complete and submit the FISAP to the U.S. Department of Education by the applicable annual deadline, and to submit any required corrections/updates by established correction deadlines. In addition, institutions must establish, document, and maintain effective internal control over federal awards and evaluate and monitor compliance with statutes, regulations, and award terms. Cause: The condition occurred because management had not established or implemented formal procedures requiring an independent review of the FISAP prior to submission, nor did it require documentation evidencing such review. As a result, responsibilities for review and approval of the FISAP were not clearly defined or enforced. Effect: The condition occurred because management had not established or implemented formal procedures requiring an independent review of the FISAP prior to submission, nor did it require documentation evidencing such review. As a result, responsibilities for review and approval of the FISAP were not clearly defined or enforced. Repeat Finding: No. Recommendation: We recommend that the Institution establish and document a formal review and approval process over the preparation and submission of the FISAP. Views of Responsible Officials: We acknowledge the auditors’ recommendation regarding the implementation of a more formalized and documented review process for the FISAP prior to submission. While no errors or compliance findings were identified as a result of the current process, we understand the value of enhancing documentation to further evidence existing internal controls. It is important to note that, based on guidance and industry practice—including input from the U.S. Department of Education’s Regional Office of Participation (Southeast Region), the National Association of Student Financial Aid Administrators, and the Florida Association of Student Financial Aid Administrators—there is no regulatory requirement mandating an independent, formally documented review of the FISAP to demonstrate compliance with internal control standards. That said, in the spirit of continuous improvement and to address the auditors’ recommendation, management will enhance its existing review procedures as follows: • The Director of Financial Aid will continue to prepare and submit the FISAP in accordance with federal requirements. • As part of the established process, the Financial Aid Business Systems Analyst and Assistant Director of Financial Aid will continue to support the review by validating data accuracy, report outputs, and proper classification within the application. • To further strengthen documentation, a standardized review checklist will be implemented and retained to evidence the review process prior to submission. These enhancements are intended to formalize and document controls already in place, while aligning with the auditors’