Finding 1137283 (2024-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-05-19
Audit: 356593
Organization: Icohs College INC (CA)

AI Summary

  • Core Issue: The institution failed to return Title IV funds on time for 31.25% of students who withdrew, violating federal regulations.
  • Impacted Requirements: Compliance with 34 CFR §668.22(j) mandates returning unearned Title IV funds within 45 days of withdrawal.
  • Recommended Follow-Up: Strengthen oversight of third-party providers, establish performance expectations, and enhance internal controls for timely processing of returns.

Finding Text

Finding 2024-002 – Special Tests and Provisions - Return of Title IV Funds Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster (84.268 Direct Loans, 84.063 Federal Pell Grant Program) Criteria: In accordance with 34 CFR §668.22(j), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment, the institution must return any unearned Title IV funds to the Department of Education within 45 calendar days from the date the institution determined the student withdrew. Condition/Context: Our initial sample of students who withdrew from the Institution was 3, and from this sample, we encountered 1 student whose required return to Title IV was late. Due to the high error rate of 1 out of 3, we expanded our testing. From a population of 20 students who withdrew and had funds returned, we selected an additional 13 students to test for the timely return of funds. The sample was based on a 90% confidence level with a 10% margin of error. Of the 16 students who withdrew and required a return of Title IV funds, we noted that in 5 cases (31.25%), the institution did not return the funds to the Department of Education within the required 45-day timeframe. Cause: The institution utilizes a third-party service provider, ECM, to calculate Return to Title IV (R2T4) amounts and transmit the required returns to the Department of Education. The institution initiates this process by completing and submitting a “Return to Title IV Request Form” to ECM. Our testing indicated that the institution submitted these forms to ECM within the required timelines. However, ECM experienced delays in processing due to significant personnel turnover and system-related issues. In April 2024, ECM notified the institution that it was updating its SOLFIA platform to comply with new Department of Education technical specifications. These updates were not completed until September 2024, after which ECM continued to experience technical issues that further delayed processing. The institution has represented that these external challenges impacted its ability to meet the 45-day deadline for returning Title IV funds. Effect: The institution was not in compliance with federal regulations regarding the timely return of Title IV funds. Late refunds could result in potential liabilities, increased scrutiny, or sanctions by the Department of Education. Questioned Costs: Known questioned costs are not considered material; however, due to the compliance nature of the finding and the frequency of occurrence, the finding is deemed material for reporting purposes. Recommendation: We recommend that the institution formally document and strengthen oversight of third-party service providers responsible for Title IV compliance. This includes establishing performance expectations, monitoring protocols, and contingency plans to ensure continuity during periods of vendor transition or system outages. We further recommend that the institution assess whether additional internal controls or staffing can supplement or verify timely R2T4 processing, particularly during periods of known vendor instability. Views of Responsible Officials and Corrective Action Plan: The institution agrees with the finding. A corrective action plan addressing the noted deficiencies has been submitted under separate cover.

Categories

Student Financial Aid Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 560839 2024-001
    Material Weakness
  • 560840 2024-001
    Material Weakness
  • 560841 2024-002
    Material Weakness
  • 560842 2024-002
    Material Weakness
  • 1137281 2024-001
    Material Weakness
  • 1137282 2024-001
    Material Weakness
  • 1137284 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
64.125 Vocational and Educational Counseling for Servicemembers and Veterans $1.42M
84.268 Federal Direct Student Loans $529,107
84.063 Federal Pell Grant Program $433,583
64.116 Vocational Rehabilitation for Disabled Veterans $424,364
64.130 Veteran Rapid Retraining Assistance Program $116,624
84.007 Federal Supplemental Educational Opportunity Grants $12,320