Finding Text
Federal Program: Title IV - Student Financial Assistance Program Cluster (AL No. 84.063 and 84.268)
Compliance Requirement: Return of Title IV Funds (R2T4) as per 34 CFR 668.22
Criteria: The College is required to ensure that R2T4 calculations are reviewed by someone other than
the person performing the original calculations to ensure accuracy and compliance.
Condition: During our review of the College's adherence to R2T4 requirements, we identified a
significant deficiency in internal controls over compliance. Specifically, there was a lack of documented
evidence showing that the R2T4 calculations were reviewed by an individual other than the one who
performed the original calculations.
Cause: The College did not have adequate procedures in place to ensure segregation of duties in the
R2T4 review process, leading to insufficient documentation of independent reviews.
Effect: The lack of segregation of duties and proper documentation could result in incorrect R2T4
calculations, non-compliance with federal regulations, and potential financial impact on the College
and its students.
Questioned Costs: None identified.
Recommendation: The college should implement procedures that ensure segregation of duties in
R2T4 calculations, designate a separate individual to review and verify the accuracy of the
calculations, and maintain comprehensive documentation to provide evidence of the review process,
including the reviewer's signature, date of review, and any findings or corrections made.
Views of responsible officials and planned corrective actions: See Corrective Action Plan