General Background Language During the 2024-2025 award year, Hult’s financial aid department effectively managed Title IV funds. Hult successfully carried out the administrative improvements implemented beginning Summer 2024. These improvements were the result of first, our own internal review of ou...
General Background Language During the 2024-2025 award year, Hult’s financial aid department effectively managed Title IV funds. Hult successfully carried out the administrative improvements implemented beginning Summer 2024. These improvements were the result of first, our own internal review of our financial aid operations, and feedback from the prior year’s 2023-2024 award year audit. The mitigating circumstances previously experienced were isolated to the 2023-2024 award year and do not reflect Hult’s ongoing ability to effectively manage Title IV funds. In the 2023-2024 corrective action plan, we noted that our goal was not just to rectify past mistakes but to build a stronger, more resilient foundation moving forward. Over the last year, we have followed through on these corrective actions, including: 1.Continued collaboration with Financial Aid Solutions (FAS) to effectively manage Hult’s core Title IV functions, including awarding, disbursement, and cash management activities, and utilize this resource for timely compliance support of our internal financial aid team 2. Conducted a full review and overhaul of our internal processes, procedures, and Regent system configuration to align with Hult’s business needs and maintain Title IV compliance 3. Maintaining a qualified, in-house financial aid team, with a focus on cross-training and succession planning, to ensure continuity and operational stability 4. Revision of our existing internal controls managed by the financial aid team, and implementing additional internal controls, independently managed by our central finance team, to ensure data accuracy, monitor for discrepancies, and enable prompt resolution of any identified issues Committing dedicated project management resources to identify process gaps, streamline operations, and optimize our use of system tools The successful implementation of these measures represents a deep and sustained investment in the integrity, compliance, and effectiveness of our Title IV operations. With these systems in place, we prevented a recurrence of last year’s findings related to the awarding, disbursement, or management of 2024-2025 Title IV funds. This year’s finding, in our view, was not a new finding, as these instances reflect a corrective action taken as a result of the 2023-2024 audit findings, with the correction happening within this recent audit period. Finding No. 2025-001 Return of Title IV Funds Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 - Federal Direct Student Loans 84.063 - Federal Pell Grant Program Responsible Individual: Marcus Friberg, VP of Finance Date Action Taken: Fiscal Year 2025 Hult acknowledges that Title IV funds were returned outside the 45-day window in four instances; however, all of which were made as a part of our corrective action plan from the FY2024 audit period. No new instances of returns outside of 45 days occurred with 2024-2025 Title IV funds. Of the four instances noted, three were directly attributable to items identified in the 2023–2024 audit, while the fourth was identified and resolved through our internal reconciliation performed to ensure no additional students were impacted. All returns of 2024-2025 Title IV funds were properly managed and made with the 45-day window. Hult’s collaboration with Financial Aid Solutions (FAS) continues to reinforce our compliance functions, cash management, and provide us with expert support. We implemented a comprehensive set of corrective actions beginning in Summer 2024 which strengthened our internal controls, which include: 1. Extensively redeveloped and tested our Regent infrastructure – in close collaboration with Regent and FAS – to ensure the system operates effectively within Hult’s academic structure, ensures the accuracy of data outputs, and maintains compliance with Title IV regulations 2. Hired a qualified, experienced, in-house financial aid team. We have, and continue, to prioritize cross-training and succession planning to ensure operational continuity 3. Implemented a dual-review process for all Title IV awards, with FAS processing calculations in Regent and Hult staff independently verifying them before disbursing funds 4. Introduced independent, recurring reconciliations of Title IV transactions by Hult’s central finance team, to ensure record accuracy and promptly resolve any issues identified These ongoing efforts have established a more resilient and accountable operational framework. We have demonstrated that with these controls in place, Hult will remain fully compliant with Title IV regulations, as there were no repeat instances of late returns in the 2024–2025 award year.