Finding 1124357 (2024-004)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351837
Organization: Guilford College (NC)
Auditor: Brown Edwards

AI Summary

  • Core Issue: Title IV refunds for two students were calculated incorrectly, indicating a significant deficiency in the process.
  • Impacted Requirements: The institution must follow 34 CFR 668.22 to accurately determine and return unearned Title IV assistance based on withdrawal dates.
  • Recommended Follow-Up: Implement procedures for accurate Title IV refund calculations and ensure staff training is comprehensive and ongoing.

Finding Text

2024-004 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Return of Title IV Refunds (Significant Deficiency) Condition: Title IV refunds for the two students tested were calculated incorrectly. Criteria: When the 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, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date in accordance with 34 CFR 668.22. The institution must return the lesser of the total amount of unearned Title IV assistance or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. Cause: Controls are not functioning properly. Effect: The amount returned was incorrect for the two students that required refund calculations. Context: From a population of 60 students that official or unofficially withdrew from a payment period, we tested nine and noted that two students required refund calculations. Repeat Finding from a Prior Year: No Recommendation: We recommend the College put procedures in place for accurate preparation and calculation of Title IV refunds. Management Response: We agree the institution must return the lesser of the total amount of unearned Title IV assistance or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. This issue arose from a lack of leadership and staff training in the Financial Aid Office over the past several years. As a result, proper procedures for calculating and returning unearned Title IV assistance were not consistently. Currently, staff are undergoing comprehensive training in all areas of Title IV and Higher Education Act (HEA) regulations. In the 2024-2025 academic year, the institution hired a new director of financial aid, who has implemented a system to process withdrawals online through Common Origination and Disbursement (COD) and has been working to maintain necessary documentation for accurate refund calculations. Additionally, an updated policies and procedures manual is being finalized to ensure that all staff members have access to the necessary resources and guidelines for compliance. If the Federal Audit Clearinghouse has questions regarding this plan, please call Danielle Pfaff, Controller at 1-336-316-2140 or dpfaff@guilford.edu.

Categories

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking Significant Deficiency

Other Findings in this Audit

  • 547915 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $6.68M
84.063 Federal Pell Grant Program $2.90M
84.031 Higher Education Institutional Aid $364,666
84.033 Federal Work-Study Program $159,965
84.007 Federal Supplemental Educational Opportunity Grants $126,864
11.020 Cluster Grants $41,253
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $35,967
19.040 Public Diplomacy Programs $19,997
47.076 Stem Education (formerly Education and Human Resources) $8,649
15.945 Cooperative Research and Training Programs – Resources of the National Park System $6,529
84.425 Education Stabilization Fund $4,367
45.129 Promotion of the Humanities Federal/state Partnership $765