Identifying Number: 2025-005: Special Tests—Credit Balances Noncompliance Finding: - During our testing of the Student Financial Assistance Cluster, we identified an instance in which the Institute did not refund a Title IV credit balance within the required 14-day time frame. Corrective Actions Tak...
Identifying Number: 2025-005: Special Tests—Credit Balances Noncompliance Finding: - During our testing of the Student Financial Assistance Cluster, we identified an instance in which the Institute did not refund a Title IV credit balance within the required 14-day time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Title IV credit balance requirements: 1. Development of Written Policies and Procedures • The Institute will develop and maintain formal written policies and procedures governing the identification, tracking, review, approval, and refunding of Title IV credit balances. Procedures will clearly define responsible personnel, required timelines, supervisory review requirements, and documentation retention standards. 2. Implementation of Credit Balance Tracking Process • Management will implement a standardized tracking process to identify Title IV credit balances immediately upon creation and monitor outstanding balances through refund issuance. The tracking log will include the student name, credit balance amount, date created, refund due date, refund date, and reviewer approval. 3. Monitoring of 14-Day Compliance Requirement • The Institute will establish controls to monitor compliance with the 14-day refund requirement, including periodic review of open credit balances and automated or manual reminders for approaching refund deadlines. Any overdue items will be escalated to management for immediate resolution. 4. Documentation of Review and Approval • Evidence of review and approval will be maintained for all Title IV credit balance refunds. Documentation will include supporting reports, refund calculations, processing dates, and supervisory approval demonstrating that refunds were processed accurately and timely. 5.Monthly Management Review • Management will perform monthly reviews of all Title IV credit balances and refund activity to verify compliance with Department of Education requirements. Review procedures will include verification that all refunds were issued within required timeframes and that supporting documentation has been retained. 7. Staff Training • Financial Aid, Student Accounts, and Finance personnel involved in processing Title IV funds will receive training on federal credit balance requirements, documentation standards, and internal control responsibilities. Training will emphasize the importance of timely refund processing and compliance monitoring. 8. Ongoing Compliance Monitoring • The Institute will periodically review credit balance activity and related controls to ensure procedures are operating effectively. Any exceptions identified will be documented, investigated, and corrected timely, with results reported to senior management. Responsible Officials: • Director of Financial Aid – Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: The Institute will fully implement credit balance tracking procedures, documentation requirements, management review controls, and staff training by December 31, 2026. Ongoing monitoring and periodic compliance reviews will continue thereafter.