Questioned Costs $ 25 Finding No. 2022 008: Inaccurate Stipend Expenditure ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.047 ? TRIO Cluster Condition During our audit of the TRIO Cluster program, we noted five instances from the Upward Bound program in which the stipend amount distributed to a program participant was not calculated in an accurate manner, resulting in an underpayment of $5 to three participants and an overpayment of $5 to two participants. We also noted four instances from the Upward Bound program in which there were discrepancies amongst the information included in various underlying supporting records used to track student participation in program activities. However, it was noted that the record ultimately used to calculate the student?s stipend accurately reflected the program activities in which they participated and thus, resulted in the distribution of an appropriate stipend. Criteria Section 200.403 ? Factors affecting allowability of costs of Title 2 U.S. CFR Part 200, states ?(c) ? in order for costs to be allowable under Federal awards it must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of non-Federal entity.? Cause The inaccurate distribution of stipends to program participants and discrepancies amongst the various underlying supporting records used to track student?s participation in program activities were attributed to computational errors during the calculation of stipend amounts and clerical errors while creating the various supporting records. Effect Failure to adhere to the allowable cost principles of Title 2 U.S. CFR Part 200 exposes the University to an undue risk of misuse of federal funds and may ultimately jeopardize the University?s ability to obtain future federal funding. Context A sample of 40 scholarship and stipend transactions totaling $9,010 in expenditures from the TRIO Cluster program was selected for audit from a population of $96,279 in scholarship and stipend expenditures from the TRIO Cluster program. Our test found 5 transactions in which an inaccurate stipend amount was distributed and 4 transactions in which discrepancies were noted in the underlying supporting records used to track a student?s participation in program activities. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the University streamline the recordkeeping function used to track student participation in program activities by reducing the number of documents currently utilized. In addition, the University should implement an additional level of review to ensure an accurate distribution of stipends utilizing funds in accordance with allowable cost criteria set forth in Title 2 U.S. CFR Part 200, subpart E. Views of Responsible Officials and Planned Corrective Actions Effective January 1, 2022, the program implemented the use of a database to assist in the tracking of student participation in program activities. Going forward, program personnel will also implement a secondary review of the calculation of stipend amounts within the database prior to the distribution of such amounts to program participants.
Questioned Costs $ 10,911 Finding No. 2022 007: Inaccurate Stipend Expenditure ? Significant Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.362 ? Title VII Native Hawaiian Education Condition During our audit of the Title VII Native Hawaiian Education (?Title VII?) program, we noted the following instances in which the stipend amount distributed to program participants was not calculated in an accurate manner: ? We noted three instances from the Hokulani program in which the criteria used to determine the amount of the stipend distributed to a program participant was not formally documented. ? We noted ten instances from the Ho?oku?i III program in which the stipend amount distributed to a program participant did not align with the documented criteria communicated to such participants. ? We noted one instance from the Kukulu Kumuhana K 3 Hawaiian Language Student and Family Literacy Project program in which the criteria used to determine the amount of the stipend distributed to a program participant was not formally documented. We also noted one instance from the Kukulu Kumuhana K 3 Hawaiian Language Student and Family Literacy Project program in which the documented process for determining and calculating the stipend distributed to a program participant was not followed. Criteria Section 200.403 ? Factors affecting allowability of costs of Title 2 U.S. CFR Part 200, states ?(c) ? in order for costs to be allowable under Federal awards it must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of non Federal entity.? Cause The inaccurate calculation and lack of documentation supporting the determination of amounts to be distributed to program participants may be attributed to a lack of oversight by program personnel. Effect Failure to adhere to the allowable cost principles of Title 2 U.S. CFR Part 200 exposes the University to an undue risk of misuse of federal funds and may ultimately jeopardize the University?s ability to obtain future federal funding. Context A sample of 40 scholarship and stipend transactions totaling $41,961 in expenditures from the Title VII program was selected for audit from a population of $865,552 in scholarship and stipend expenditures from the Title VII program. Our test found 15 transactions in which the criteria applied to calculate the stipend amount was inadequately documented or the program?s policies for determining and awarding stipends was not followed. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2021 006. Recommendation We recommend that the University ensure that adequate documentation is maintained detailing the criteria used to calculate the awarded stipends and that policies for determining and awarding stipends are appropriately followed to ensure an accurate distribution of stipends utilizing funds within the context of Title 2 U.S. CFR 200, subpart E. Views of Responsible Officials and Planned Corrective Actions Hokulani and Ho?oku?i III Programs Program personnel have been reminded that any changes or variations to project stipend payments must be communicated to all participants prior to the changes or variations taking effect and that the criteria used to formulate stipend payments must be formally documented. Kukulu Kumuhana K-3 Hawaiian Language Student and Family Literacy Project Program Program personnel have updated their procedures to ensure that the criteria applied during the calculation of stipend payments is properly documented.
Questioned Costs $ -0- Finding No. 2022 001: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program Condition During our audit, for 1 out of 15 students selected for testing, the institution failed to remit all disbursed Title IV Funds to the Title IV program within 30 days after the institution became aware that the student did not begin attendance. Criteria Title 34, Section 668.21(a) through (b) of the U.S. Code of Federal Regulations (?CFR?) requires if a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, Higher Education Act (?HEA?) program funds that were credited to the student?s account at the institution or disbursed directly to the student for that payment period or period of enrollment for Federal Perkins Loan, Federal Supplemental Educational Opportunity Grant, Federal Pell Grant, Teacher Education Assistance for College and Higher Education Grant, Academic Competitiveness Grant, and National Science and Mathematics Access to Retain Talent Grant program funds. For Federal Direct Student Loans, the institution must return all funds that were credited to the student?s account at the institution for that payment period or period of enrollment. The institution must return those funds for which it is responsible for the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return to Title IV calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $105,403 in Title IV funds was selected for audit from a population of 480 students who withdrew and were disbursed a total of $4,138,083 in Title IV funds. Our test found 1 student?s institutional portion of unearned aid was remitted untimely. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal requirements: ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 30 day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution will work with the Office of the Registrar to confirm student attendance as needed to ensure compliance with federal reporting guidelines and to enable the institution to prepare the return of Title IV calculation in a timely manner.
Questioned Costs $ 812 Finding No. 2022 002: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: Return of Title IV Funds ? For 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $812 to the Title IV program. ? For 3 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. ? For 1 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. Direct Student Loans ? During our audit, for 1 out of 3 months selected for testing, the institution did not have evidence that they were transmitting and properly reconciling borrower data. As such, the institution failed to perform the reconciliation between institutional records and direct loan disbursement records. Criteria Return of Title IV Funds Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew. Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Direct Student Loans Title 34, Section 685.30(b)(5) of the CFR requires the institution to reconcile institution records with direct loan funds received from the Secretary of Education and direct loan disbursement records submitted to and accepted by the Secretary of Education on a monthly basis. Cause Return of Title IV Funds Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Direct Student Loans Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to perform the month end direct loan reconciliation process. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context Return of Title IV Funds A sample of 15 students who withdrew from the institution and were disbursed a total of $40,116 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 1 student?s return of Title IV funds was incorrectly calculated, resulting in a total questioned cost of $812. Our sample was a statistically valid sample. A sample of 15 students who withdrew from the institution and were disbursed a total of $40,116 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 3 students? return to Title IV calculation performed untimely. Our sample was a statistically valid sample. A sample of 15 students who withdrew from the institution and were disbursed a total of $41,248 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 1 student?s return of Title IV funds was not remitted timely. Our sample was a statistically valid sample. Direct Student Loans A sample of 3 monthly reconciliations was selected for audit from a population of 12 monthly reconciliations. Our test found that the institution was unable to provide us with the requested reconciliations for 1 out of our 3 sampled months. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal requirements: Return of Title IV Funds ? Ensure that the correct information is used to prepare the return of Title IV calculation. ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45 day time period in accordance with federal regulations. ? Determine the withdrawal date for students who unofficially withdrew from the institution within the required 30 day time period in accordance with federal regulations. ? Remit all aid to the appropriate Title IV programs if a student fails to begin attendance during the period of enrollment. Direct Student Loans ? We recommend that the institution reconcile borrower information on a monthly basis, retain records to ensure compliance with Federal requirements, and retain secondary copies of the reconciliation support. Views of Responsible Officials and Planned Corrective Actions Return of Title IV Funds The institution is currently in the process of hiring additional personnel to assist in the preparation of the return of Title IV calculation. To ensure compliance with federal reporting guidelines, the institution will provide personnel with additional training on the return of Title IV calculation and develop a processing schedule to assist in the completion of the return of Title IV calculation in a timely and accurate manner. Direct Student Loans The institution will provide personnel with additional training on the loan reconciliation process and develop a schedule to assist in the completion of the loan reconciliation process in a timely and accurate manner.
Questioned Costs $ 812 Finding No. 2022 002: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: Return of Title IV Funds ? For 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $812 to the Title IV program. ? For 3 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. ? For 1 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. Direct Student Loans ? During our audit, for 1 out of 3 months selected for testing, the institution did not have evidence that they were transmitting and properly reconciling borrower data. As such, the institution failed to perform the reconciliation between institutional records and direct loan disbursement records. Criteria Return of Title IV Funds Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew. Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Direct Student Loans Title 34, Section 685.30(b)(5) of the CFR requires the institution to reconcile institution records with direct loan funds received from the Secretary of Education and direct loan disbursement records submitted to and accepted by the Secretary of Education on a monthly basis. Cause Return of Title IV Funds Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Direct Student Loans Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to perform the month end direct loan reconciliation process. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context Return of Title IV Funds A sample of 15 students who withdrew from the institution and were disbursed a total of $40,116 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 1 student?s return of Title IV funds was incorrectly calculated, resulting in a total questioned cost of $812. Our sample was a statistically valid sample. A sample of 15 students who withdrew from the institution and were disbursed a total of $40,116 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 3 students? return to Title IV calculation performed untimely. Our sample was a statistically valid sample. A sample of 15 students who withdrew from the institution and were disbursed a total of $41,248 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 1 student?s return of Title IV funds was not remitted timely. Our sample was a statistically valid sample. Direct Student Loans A sample of 3 monthly reconciliations was selected for audit from a population of 12 monthly reconciliations. Our test found that the institution was unable to provide us with the requested reconciliations for 1 out of our 3 sampled months. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal requirements: Return of Title IV Funds ? Ensure that the correct information is used to prepare the return of Title IV calculation. ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45 day time period in accordance with federal regulations. ? Determine the withdrawal date for students who unofficially withdrew from the institution within the required 30 day time period in accordance with federal regulations. ? Remit all aid to the appropriate Title IV programs if a student fails to begin attendance during the period of enrollment. Direct Student Loans ? We recommend that the institution reconcile borrower information on a monthly basis, retain records to ensure compliance with Federal requirements, and retain secondary copies of the reconciliation support. Views of Responsible Officials and Planned Corrective Actions Return of Title IV Funds The institution is currently in the process of hiring additional personnel to assist in the preparation of the return of Title IV calculation. To ensure compliance with federal reporting guidelines, the institution will provide personnel with additional training on the return of Title IV calculation and develop a processing schedule to assist in the completion of the return of Title IV calculation in a timely and accurate manner. Direct Student Loans The institution will provide personnel with additional training on the loan reconciliation process and develop a schedule to assist in the completion of the loan reconciliation process in a timely and accurate manner.
Questioned Costs $ 670 Finding No. 2022 003: Return of Title IV Funds ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program Condition During our audit, for 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $670 to the Title IV program. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew. Cause Due to an oversight by one of the financial aid office staff, the institution?s required return amount was not returned to the Title IV program despite a calculation being performed. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $55,745 in Title IV funds was selected for audit from a population of 457 students who withdrew and were disbursed a total of $926,438 in Title IV funds. Our test found 1 student?s return of Title IV funds was not remitted timely, resulting in a total questioned cost of $670. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2021 004. Recommendation We recommend that the institution remit the institutional portion of unearned aid to the appropriate Title IV program within the required time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has updated its procedures to include an additional step to confirm that all required returns have been processed and returned. Personnel will also be assigned to review the completed return of Title IV calculations on a weekly basis to ensure the calculation was performed in a timely and accurate manner.
Questioned Costs $ -0- Finding No. 2022 004: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 ? Federal Direct Student Loans Condition During our audit, for 2 out of 3 months selected for testing, the institution did not have evidence that they were transmitting and properly reconciling borrower data. As the institution could not provide evidence that they performed the reconciliation between institutional records and direct loan disbursement records, we deem the reconciliation to not have been performed. Criteria Title 34, Section 685.30(b)(5) of the CFR requires the institution to reconcile institution records with direct loan funds received from the Secretary of Education and direct loan disbursement records submitted to and accepted by the Secretary of Education on a monthly basis. Cause Due to an unexpected malfunction of the institution?s data server, all evidence that the monthly reconciliation process was completed prior to March 2022 was lost. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 3 monthly reconciliations was selected for audit from a population of 12 monthly reconciliations. Our test found that the institution was unable to provide us with the requested reconciliations for 2 out of our 3 sampled months. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution reconcile borrower information on a monthly basis, retain records to ensure compliance with Federal requirements, and retain secondary copies of the reconciliation support. Views of Responsible Officials and Planned Corrective Actions In November 2022, the institution implemented procedures to back up documentation supporting the transmittal and reconciliation of borrower data on at least a quarterly basis.
Questioned Costs $ -0- Finding No. 2022 005: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 ? Federal Direct Student Loans Condition During our audit, for 1 out of 3 months selected for testing, the institution did not have evidence that they were transmitting and properly reconciling borrower data. As such, the institution failed to perform the reconciliation between institutional records and direct loan disbursement records. Criteria Title 34, Section 685.30(b)(5) of the CFR requires the institution to reconcile institution records with direct loan funds received from the Secretary of Education and direct loan disbursement records submitted to and accepted by the Secretary of Education on a monthly basis. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to perform the month end direct loan reconciliation process. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 3 monthly reconciliations was selected for audit from a population of 12 monthly reconciliations. Our test found that the institution was unable to provide us with the requested reconciliations for 1 out of our 3 sampled months. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution reconcile borrower information on a monthly basis, retain records to ensure compliance with Federal requirements, and retain secondary copies of the reconciliation support. Views of Responsible Officials and Planned Corrective Actions The institution has updated its procedures to assist in the completion of the transmittal and reconciliation of borrower data in a timely manner.
Questioned Costs $ -0- Finding No. 2022 006: Return of Title IV Funds ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: ? For 4 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. ? For 6 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. Criteria Title 34, Section 668.173(b) of the CFR requires the institutional portion of unearned aid to be returned to the appropriate Title IV, HEA program or Federal Family Education Loan lender no later than 45 days after the date of the institution?s determination that the student withdrew. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Cause Due to turnover in critical positions within the financial aid office, the institution was unable to accurately perform the return of Title IV calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $49,002 in Title IV funds was selected for audit from a population of 120 students who withdrew and were disbursed a total of $358,323 in Title IV funds. Our test found that 4 students? institutional portion of unearned aid was remitted untimely and the institution failed to determine the withdrawal date in a timely manner for 6 students. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with federal regulations: ? Determine the withdrawal date for students who withdrew without providing notification within 30 days after the end of the period of enrollment in accordance with federal regulations. ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45 day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution is currently training additional personnel to assist with the return of Title IV calculations. Personnel will also be assigned to review the completed return of Title IV calculations on a weekly basis to ensure the calculation was performed in a timely and accurate manner.
Questioned Costs $ -0- Finding No. 2022 006: Return of Title IV Funds ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: ? For 4 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. ? For 6 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. Criteria Title 34, Section 668.173(b) of the CFR requires the institutional portion of unearned aid to be returned to the appropriate Title IV, HEA program or Federal Family Education Loan lender no later than 45 days after the date of the institution?s determination that the student withdrew. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Cause Due to turnover in critical positions within the financial aid office, the institution was unable to accurately perform the return of Title IV calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $49,002 in Title IV funds was selected for audit from a population of 120 students who withdrew and were disbursed a total of $358,323 in Title IV funds. Our test found that 4 students? institutional portion of unearned aid was remitted untimely and the institution failed to determine the withdrawal date in a timely manner for 6 students. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with federal regulations: ? Determine the withdrawal date for students who withdrew without providing notification within 30 days after the end of the period of enrollment in accordance with federal regulations. ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45 day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution is currently training additional personnel to assist with the return of Title IV calculations. Personnel will also be assigned to review the completed return of Title IV calculations on a weekly basis to ensure the calculation was performed in a timely and accurate manner.
Questioned Costs $ 25 Finding No. 2022 008: Inaccurate Stipend Expenditure ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.047 ? TRIO Cluster Condition During our audit of the TRIO Cluster program, we noted five instances from the Upward Bound program in which the stipend amount distributed to a program participant was not calculated in an accurate manner, resulting in an underpayment of $5 to three participants and an overpayment of $5 to two participants. We also noted four instances from the Upward Bound program in which there were discrepancies amongst the information included in various underlying supporting records used to track student participation in program activities. However, it was noted that the record ultimately used to calculate the student?s stipend accurately reflected the program activities in which they participated and thus, resulted in the distribution of an appropriate stipend. Criteria Section 200.403 ? Factors affecting allowability of costs of Title 2 U.S. CFR Part 200, states ?(c) ? in order for costs to be allowable under Federal awards it must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of non-Federal entity.? Cause The inaccurate distribution of stipends to program participants and discrepancies amongst the various underlying supporting records used to track student?s participation in program activities were attributed to computational errors during the calculation of stipend amounts and clerical errors while creating the various supporting records. Effect Failure to adhere to the allowable cost principles of Title 2 U.S. CFR Part 200 exposes the University to an undue risk of misuse of federal funds and may ultimately jeopardize the University?s ability to obtain future federal funding. Context A sample of 40 scholarship and stipend transactions totaling $9,010 in expenditures from the TRIO Cluster program was selected for audit from a population of $96,279 in scholarship and stipend expenditures from the TRIO Cluster program. Our test found 5 transactions in which an inaccurate stipend amount was distributed and 4 transactions in which discrepancies were noted in the underlying supporting records used to track a student?s participation in program activities. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the University streamline the recordkeeping function used to track student participation in program activities by reducing the number of documents currently utilized. In addition, the University should implement an additional level of review to ensure an accurate distribution of stipends utilizing funds in accordance with allowable cost criteria set forth in Title 2 U.S. CFR Part 200, subpart E. Views of Responsible Officials and Planned Corrective Actions Effective January 1, 2022, the program implemented the use of a database to assist in the tracking of student participation in program activities. Going forward, program personnel will also implement a secondary review of the calculation of stipend amounts within the database prior to the distribution of such amounts to program participants.
Questioned Costs $ 10,911 Finding No. 2022 007: Inaccurate Stipend Expenditure ? Significant Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.362 ? Title VII Native Hawaiian Education Condition During our audit of the Title VII Native Hawaiian Education (?Title VII?) program, we noted the following instances in which the stipend amount distributed to program participants was not calculated in an accurate manner: ? We noted three instances from the Hokulani program in which the criteria used to determine the amount of the stipend distributed to a program participant was not formally documented. ? We noted ten instances from the Ho?oku?i III program in which the stipend amount distributed to a program participant did not align with the documented criteria communicated to such participants. ? We noted one instance from the Kukulu Kumuhana K 3 Hawaiian Language Student and Family Literacy Project program in which the criteria used to determine the amount of the stipend distributed to a program participant was not formally documented. We also noted one instance from the Kukulu Kumuhana K 3 Hawaiian Language Student and Family Literacy Project program in which the documented process for determining and calculating the stipend distributed to a program participant was not followed. Criteria Section 200.403 ? Factors affecting allowability of costs of Title 2 U.S. CFR Part 200, states ?(c) ? in order for costs to be allowable under Federal awards it must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of non Federal entity.? Cause The inaccurate calculation and lack of documentation supporting the determination of amounts to be distributed to program participants may be attributed to a lack of oversight by program personnel. Effect Failure to adhere to the allowable cost principles of Title 2 U.S. CFR Part 200 exposes the University to an undue risk of misuse of federal funds and may ultimately jeopardize the University?s ability to obtain future federal funding. Context A sample of 40 scholarship and stipend transactions totaling $41,961 in expenditures from the Title VII program was selected for audit from a population of $865,552 in scholarship and stipend expenditures from the Title VII program. Our test found 15 transactions in which the criteria applied to calculate the stipend amount was inadequately documented or the program?s policies for determining and awarding stipends was not followed. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2021 006. Recommendation We recommend that the University ensure that adequate documentation is maintained detailing the criteria used to calculate the awarded stipends and that policies for determining and awarding stipends are appropriately followed to ensure an accurate distribution of stipends utilizing funds within the context of Title 2 U.S. CFR 200, subpart E. Views of Responsible Officials and Planned Corrective Actions Hokulani and Ho?oku?i III Programs Program personnel have been reminded that any changes or variations to project stipend payments must be communicated to all participants prior to the changes or variations taking effect and that the criteria used to formulate stipend payments must be formally documented. Kukulu Kumuhana K-3 Hawaiian Language Student and Family Literacy Project Program Program personnel have updated their procedures to ensure that the criteria applied during the calculation of stipend payments is properly documented.
Questioned Costs $ -0- Finding No. 2022 001: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program Condition During our audit, for 1 out of 15 students selected for testing, the institution failed to remit all disbursed Title IV Funds to the Title IV program within 30 days after the institution became aware that the student did not begin attendance. Criteria Title 34, Section 668.21(a) through (b) of the U.S. Code of Federal Regulations (?CFR?) requires if a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, Higher Education Act (?HEA?) program funds that were credited to the student?s account at the institution or disbursed directly to the student for that payment period or period of enrollment for Federal Perkins Loan, Federal Supplemental Educational Opportunity Grant, Federal Pell Grant, Teacher Education Assistance for College and Higher Education Grant, Academic Competitiveness Grant, and National Science and Mathematics Access to Retain Talent Grant program funds. For Federal Direct Student Loans, the institution must return all funds that were credited to the student?s account at the institution for that payment period or period of enrollment. The institution must return those funds for which it is responsible for the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return to Title IV calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $105,403 in Title IV funds was selected for audit from a population of 480 students who withdrew and were disbursed a total of $4,138,083 in Title IV funds. Our test found 1 student?s institutional portion of unearned aid was remitted untimely. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal requirements: ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 30 day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution will work with the Office of the Registrar to confirm student attendance as needed to ensure compliance with federal reporting guidelines and to enable the institution to prepare the return of Title IV calculation in a timely manner.
Questioned Costs $ 812 Finding No. 2022 002: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: Return of Title IV Funds ? For 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $812 to the Title IV program. ? For 3 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. ? For 1 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. Direct Student Loans ? During our audit, for 1 out of 3 months selected for testing, the institution did not have evidence that they were transmitting and properly reconciling borrower data. As such, the institution failed to perform the reconciliation between institutional records and direct loan disbursement records. Criteria Return of Title IV Funds Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew. Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Direct Student Loans Title 34, Section 685.30(b)(5) of the CFR requires the institution to reconcile institution records with direct loan funds received from the Secretary of Education and direct loan disbursement records submitted to and accepted by the Secretary of Education on a monthly basis. Cause Return of Title IV Funds Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Direct Student Loans Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to perform the month end direct loan reconciliation process. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context Return of Title IV Funds A sample of 15 students who withdrew from the institution and were disbursed a total of $40,116 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 1 student?s return of Title IV funds was incorrectly calculated, resulting in a total questioned cost of $812. Our sample was a statistically valid sample. A sample of 15 students who withdrew from the institution and were disbursed a total of $40,116 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 3 students? return to Title IV calculation performed untimely. Our sample was a statistically valid sample. A sample of 15 students who withdrew from the institution and were disbursed a total of $41,248 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 1 student?s return of Title IV funds was not remitted timely. Our sample was a statistically valid sample. Direct Student Loans A sample of 3 monthly reconciliations was selected for audit from a population of 12 monthly reconciliations. Our test found that the institution was unable to provide us with the requested reconciliations for 1 out of our 3 sampled months. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal requirements: Return of Title IV Funds ? Ensure that the correct information is used to prepare the return of Title IV calculation. ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45 day time period in accordance with federal regulations. ? Determine the withdrawal date for students who unofficially withdrew from the institution within the required 30 day time period in accordance with federal regulations. ? Remit all aid to the appropriate Title IV programs if a student fails to begin attendance during the period of enrollment. Direct Student Loans ? We recommend that the institution reconcile borrower information on a monthly basis, retain records to ensure compliance with Federal requirements, and retain secondary copies of the reconciliation support. Views of Responsible Officials and Planned Corrective Actions Return of Title IV Funds The institution is currently in the process of hiring additional personnel to assist in the preparation of the return of Title IV calculation. To ensure compliance with federal reporting guidelines, the institution will provide personnel with additional training on the return of Title IV calculation and develop a processing schedule to assist in the completion of the return of Title IV calculation in a timely and accurate manner. Direct Student Loans The institution will provide personnel with additional training on the loan reconciliation process and develop a schedule to assist in the completion of the loan reconciliation process in a timely and accurate manner.
Questioned Costs $ 812 Finding No. 2022 002: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: Return of Title IV Funds ? For 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $812 to the Title IV program. ? For 3 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. ? For 1 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. Direct Student Loans ? During our audit, for 1 out of 3 months selected for testing, the institution did not have evidence that they were transmitting and properly reconciling borrower data. As such, the institution failed to perform the reconciliation between institutional records and direct loan disbursement records. Criteria Return of Title IV Funds Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew. Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Direct Student Loans Title 34, Section 685.30(b)(5) of the CFR requires the institution to reconcile institution records with direct loan funds received from the Secretary of Education and direct loan disbursement records submitted to and accepted by the Secretary of Education on a monthly basis. Cause Return of Title IV Funds Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Direct Student Loans Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to perform the month end direct loan reconciliation process. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context Return of Title IV Funds A sample of 15 students who withdrew from the institution and were disbursed a total of $40,116 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 1 student?s return of Title IV funds was incorrectly calculated, resulting in a total questioned cost of $812. Our sample was a statistically valid sample. A sample of 15 students who withdrew from the institution and were disbursed a total of $40,116 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 3 students? return to Title IV calculation performed untimely. Our sample was a statistically valid sample. A sample of 15 students who withdrew from the institution and were disbursed a total of $41,248 in Title IV funds was selected for audit from a population of 199 students who withdrew and were disbursed a total of $337,507 in Title IV funds. Our test found 1 student?s return of Title IV funds was not remitted timely. Our sample was a statistically valid sample. Direct Student Loans A sample of 3 monthly reconciliations was selected for audit from a population of 12 monthly reconciliations. Our test found that the institution was unable to provide us with the requested reconciliations for 1 out of our 3 sampled months. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal requirements: Return of Title IV Funds ? Ensure that the correct information is used to prepare the return of Title IV calculation. ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45 day time period in accordance with federal regulations. ? Determine the withdrawal date for students who unofficially withdrew from the institution within the required 30 day time period in accordance with federal regulations. ? Remit all aid to the appropriate Title IV programs if a student fails to begin attendance during the period of enrollment. Direct Student Loans ? We recommend that the institution reconcile borrower information on a monthly basis, retain records to ensure compliance with Federal requirements, and retain secondary copies of the reconciliation support. Views of Responsible Officials and Planned Corrective Actions Return of Title IV Funds The institution is currently in the process of hiring additional personnel to assist in the preparation of the return of Title IV calculation. To ensure compliance with federal reporting guidelines, the institution will provide personnel with additional training on the return of Title IV calculation and develop a processing schedule to assist in the completion of the return of Title IV calculation in a timely and accurate manner. Direct Student Loans The institution will provide personnel with additional training on the loan reconciliation process and develop a schedule to assist in the completion of the loan reconciliation process in a timely and accurate manner.
Questioned Costs $ 670 Finding No. 2022 003: Return of Title IV Funds ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program Condition During our audit, for 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $670 to the Title IV program. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew. Cause Due to an oversight by one of the financial aid office staff, the institution?s required return amount was not returned to the Title IV program despite a calculation being performed. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $55,745 in Title IV funds was selected for audit from a population of 457 students who withdrew and were disbursed a total of $926,438 in Title IV funds. Our test found 1 student?s return of Title IV funds was not remitted timely, resulting in a total questioned cost of $670. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2021 004. Recommendation We recommend that the institution remit the institutional portion of unearned aid to the appropriate Title IV program within the required time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has updated its procedures to include an additional step to confirm that all required returns have been processed and returned. Personnel will also be assigned to review the completed return of Title IV calculations on a weekly basis to ensure the calculation was performed in a timely and accurate manner.
Questioned Costs $ -0- Finding No. 2022 004: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 ? Federal Direct Student Loans Condition During our audit, for 2 out of 3 months selected for testing, the institution did not have evidence that they were transmitting and properly reconciling borrower data. As the institution could not provide evidence that they performed the reconciliation between institutional records and direct loan disbursement records, we deem the reconciliation to not have been performed. Criteria Title 34, Section 685.30(b)(5) of the CFR requires the institution to reconcile institution records with direct loan funds received from the Secretary of Education and direct loan disbursement records submitted to and accepted by the Secretary of Education on a monthly basis. Cause Due to an unexpected malfunction of the institution?s data server, all evidence that the monthly reconciliation process was completed prior to March 2022 was lost. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 3 monthly reconciliations was selected for audit from a population of 12 monthly reconciliations. Our test found that the institution was unable to provide us with the requested reconciliations for 2 out of our 3 sampled months. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution reconcile borrower information on a monthly basis, retain records to ensure compliance with Federal requirements, and retain secondary copies of the reconciliation support. Views of Responsible Officials and Planned Corrective Actions In November 2022, the institution implemented procedures to back up documentation supporting the transmittal and reconciliation of borrower data on at least a quarterly basis.
Questioned Costs $ -0- Finding No. 2022 005: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 ? Federal Direct Student Loans Condition During our audit, for 1 out of 3 months selected for testing, the institution did not have evidence that they were transmitting and properly reconciling borrower data. As such, the institution failed to perform the reconciliation between institutional records and direct loan disbursement records. Criteria Title 34, Section 685.30(b)(5) of the CFR requires the institution to reconcile institution records with direct loan funds received from the Secretary of Education and direct loan disbursement records submitted to and accepted by the Secretary of Education on a monthly basis. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to perform the month end direct loan reconciliation process. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 3 monthly reconciliations was selected for audit from a population of 12 monthly reconciliations. Our test found that the institution was unable to provide us with the requested reconciliations for 1 out of our 3 sampled months. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution reconcile borrower information on a monthly basis, retain records to ensure compliance with Federal requirements, and retain secondary copies of the reconciliation support. Views of Responsible Officials and Planned Corrective Actions The institution has updated its procedures to assist in the completion of the transmittal and reconciliation of borrower data in a timely manner.
Questioned Costs $ -0- Finding No. 2022 006: Return of Title IV Funds ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: ? For 4 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. ? For 6 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. Criteria Title 34, Section 668.173(b) of the CFR requires the institutional portion of unearned aid to be returned to the appropriate Title IV, HEA program or Federal Family Education Loan lender no later than 45 days after the date of the institution?s determination that the student withdrew. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Cause Due to turnover in critical positions within the financial aid office, the institution was unable to accurately perform the return of Title IV calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $49,002 in Title IV funds was selected for audit from a population of 120 students who withdrew and were disbursed a total of $358,323 in Title IV funds. Our test found that 4 students? institutional portion of unearned aid was remitted untimely and the institution failed to determine the withdrawal date in a timely manner for 6 students. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with federal regulations: ? Determine the withdrawal date for students who withdrew without providing notification within 30 days after the end of the period of enrollment in accordance with federal regulations. ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45 day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution is currently training additional personnel to assist with the return of Title IV calculations. Personnel will also be assigned to review the completed return of Title IV calculations on a weekly basis to ensure the calculation was performed in a timely and accurate manner.
Questioned Costs $ -0- Finding No. 2022 006: Return of Title IV Funds ? Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: ? For 4 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. ? For 6 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. Criteria Title 34, Section 668.173(b) of the CFR requires the institutional portion of unearned aid to be returned to the appropriate Title IV, HEA program or Federal Family Education Loan lender no later than 45 days after the date of the institution?s determination that the student withdrew. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Cause Due to turnover in critical positions within the financial aid office, the institution was unable to accurately perform the return of Title IV calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $49,002 in Title IV funds was selected for audit from a population of 120 students who withdrew and were disbursed a total of $358,323 in Title IV funds. Our test found that 4 students? institutional portion of unearned aid was remitted untimely and the institution failed to determine the withdrawal date in a timely manner for 6 students. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with federal regulations: ? Determine the withdrawal date for students who withdrew without providing notification within 30 days after the end of the period of enrollment in accordance with federal regulations. ? Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45 day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution is currently training additional personnel to assist with the return of Title IV calculations. Personnel will also be assigned to review the completed return of Title IV calculations on a weekly basis to ensure the calculation was performed in a timely and accurate manner.