Finding 1101408 (2024-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2024
Accepted
2025-02-28
Audit: 344308
Organization: National University (CA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: There is a material weakness in internal controls regarding the timely identification of withdrawn students and the accurate return of Title IV funds.
  • Impacted Requirements: Compliance with 34 CFR section 668.22, which mandates timely withdrawal determinations and fund returns within specified timeframes.
  • Recommended Follow-Up: NU should assess and improve its processes for identifying withdrawn students and ensure accurate and timely returns of Title IV funds.

Finding Text

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system. For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students Cause – The University does not have an effective process in place to ensure all withdrawn students are timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236. Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding – This is a repeat finding, see 2023-001. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.

Categories

Questioned Costs Special Tests & Provisions Student Financial Aid Subrecipient Monitoring Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 524963 2024-001
    Material Weakness Repeat
  • 524964 2024-001
    Material Weakness Repeat
  • 524965 2024-001
    Material Weakness Repeat
  • 524966 2024-001
    Material Weakness Repeat
  • 524967 2024-001
    Material Weakness Repeat
  • 524968 2024-002
    Material Weakness Repeat
  • 524969 2024-002
    Material Weakness Repeat
  • 524970 2024-002
    Material Weakness Repeat
  • 524971 2024-002
    Material Weakness Repeat
  • 524972 2024-002
    Material Weakness Repeat
  • 1101405 2024-001
    Material Weakness Repeat
  • 1101406 2024-001
    Material Weakness Repeat
  • 1101407 2024-001
    Material Weakness Repeat
  • 1101409 2024-001
    Material Weakness Repeat
  • 1101410 2024-002
    Material Weakness Repeat
  • 1101411 2024-002
    Material Weakness Repeat
  • 1101412 2024-002
    Material Weakness Repeat
  • 1101413 2024-002
    Material Weakness Repeat
  • 1101414 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $263.92M
84.063 Federal Pell Grant Program $20.76M
84.379 Teacher Education Assistance for College and Higher Education (teach) Grants $2.77M
84.336 Teacher Quality Partnership Grant Program (aspire) $928,709
84.038 Federal Perkins Loan Program $856,477
84.031 Developing Hispanic-Serving Institutions Program (access) $644,805
84.411 Education Innovation Research $622,586
84.007 Federal Supplemental Educational Opportunity Grants Program $461,014
84.215 Innovative Approaches to Literacy (enlaces) $267,354
84.033 Federal Work Study Program $118,500
12.903 Gencyber Grants Program $107,964
47.070 Biology Gucsd- Tilos Subaward $93,039
47.076 Biology Through Art $91,536
84.116 Fund for the Improvement of Postsecondary Education (nu Peer Navigator Network) $76,965
12.902 Cyber Scholarship Grant $49,574
93.359 Nurse Education, Practice Quality and Retention Grants $33,234