Finding 1127613 (2024-101)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: The District failed to return $943 of Title IV funds for one student who withdrew, violating federal regulations and internal policies.
  • Impacted Requirements: Compliance with federal regulations requires returning unearned Title IV funds when a student withdraws, which was not properly calculated due to system control failures.
  • Recommended Follow-Up: Calculate and return unearned aid for all affected students, update the student information system to flag withdrawals, and test system changes to ensure compliance.

Finding Text

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A230133, P033A230133, P063P230512, P063Q230512, and P268K230512 July 1, 2023 through June 30, 2024 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions - return of Title IV funds Questioned costs: $943 Condition—Contrary to federal regulation and the District’s policies and procedures, the District’s Financial Aid and Scholarships Department (Department) did not return $943 of Student Financial Assistance’s (SFA) Title IV funds for 1 student who received grants and loans and withdrew during a payment period or period of enrollment in which the student began attendance.1 Specifically, for 1 of 25 students tested, the District did not complete the required calculation and return the $943 unearned portion of a student’s $3,698 original Pell grant award to the U.S. Department of Education (ED) after the student withdrew from the District. Effect—The District’s not returning $943 of Title IV funds to ED resulted in Title IV funds not being spent as intended by program requirements. Further, there is an increased risk that the District may need to return additional Title IV funds to ED. For example, the Department’s Management reported that it identified an additional 81 students, or $153,318 in Title IV funds, for whom it did not perform required calculations during the period November 2023 through June 30, 2024. This includes $143,509 in Pell Grants, $5,718 in Direct Loans, $3,716 in Federal Work Study, and $375 in Federal Supplemental Educational Opportunity Grants that may not have been spent as intended by program requirements. Cause—The District’s student information system’s automated controls did not flag students who withdrew and required a return to Title IV calculation. In November 2023, the District made changes to its student information system without performing tests to ensure the automated controls were properly identifying and flagging students who withdrew. Criteria—Federal regulation and District policies and procedures require the return of Title IV funds when a recipient of Title IV grant or loan assistance withdraws from the District during a payment period or period of enrollment in which the recipient began attendance. Specifically, the District must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs (34 Code of Federal Regulations [CFR] §668.22[a][1-5]).2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Perform calculations for all students who received Title IV funds and withdrew during the period November 2023 through June 2024 and immediately return all unearned aid to ED. 2. Review and update the student information system’s automated controls to properly identify and flag all students who receive Title IV funds and withdraw from the District. 3. Test any changes made to the student information system and verify controls are operating as designed to comply with the SFA cluster’s requirements. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The Title IV programs as part of the Student Financial Assistance cluster are administered by the Department of Education (those with Assistance Listings beginning with 84) and authorized by Title IV of the Higher Education Act of 1965, as amended (HEA), and collectively are referred to as the “Title IV programs.” 2 Pima County Community College District. (2023). Pima County Community College District Policy and Procedures 2023-2024 V2. Page 253 of 272.

Categories

Questioned Costs Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 551168 2024-101
    Significant Deficiency
  • 551169 2024-101
    Significant Deficiency
  • 551170 2024-101
    Significant Deficiency
  • 551171 2024-101
    Significant Deficiency
  • 1127610 2024-101
    Significant Deficiency
  • 1127611 2024-101
    Significant Deficiency
  • 1127612 2024-101
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $25.88M
84.268 Federal Direct Student Loans $6.59M
84.002 Adult Education - Basic Grants to States $3.18M
84.031 Higher Education_institutional Aid $2.67M
84.047 Trio_upward Bound $1.92M
84.042 Trio_student Support Services $784,953
93.516 Public Health Training Centers Program $655,262
84.033 Federal Work-Study Program $594,023
84.044 Trio_talent Search $580,027
84.007 Federal Supplemental Educational Opportunity Grants $484,767
84.048 Career and Technical Education -- Basic Grants to States $475,125
20.112 Aviation Maintenance Technical Workforce Grant Program $372,600
17.268 H-1b Job Training Grants $297,525
21.027 Coronavirus State and Local Fiscal Recovery Funds $199,792
84.335 Child Care Access Means Parents in School $184,446
59.037 Small Business Development Centers $168,504
20.701 University Transportation Centers Program $89,309
15.659 National Wildlife Refuge Fund $79,591
17.270 Reintegration of Ex-Offenders $79,524
47.076 Stem Education (formerly Education and Human Resources) $54,261
43.008 Office of Stem Engagement (ostem) $47,833
97.010 Citizenship Education and Training $28,816
11.307 Economic Adjustment Assistance $25,000
20.616 National Priority Safety Programs $21,973
17.259 Wia Youth Activities $15,953