Finding 1157283 (2024-001)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2025-09-30

AI Summary

  • Core Issue: Four out of 22 students with Title IV credit balances did not receive their funds on time, violating federal regulations.
  • Impacted Requirements: Institutions must disburse Title IV credit balances within 14 days to avoid financial hardship for students.
  • Recommended Follow-Up: Improve monitoring and internal controls to ensure timely disbursement of credit balances.

Finding Text

Finding 2024-001 Credit Balances Condition: We tested a sample of 40 students, of which 22 had Title IV credit balances during the year. For four of these 22 students, the Institution did not disburse the credit balances within the required timeframe. The sample was selected using a statistical methodology designed to achieve a 90% confidence level. The resulting error rate (18.2%) exceeded our materiality threshold of 10%. Further, this same issue was noted in a recent U.S. Department of Education program review. Accordingly, expanding the sample would not reduce the materiality of this finding. Criteria: In accordance with 34 CFR §668.164(e), when a Title IV credit balance exists, an institution must pay the credit balance directly to the student (or parent, if applicable) as soon as possible, but no later than 14 calendar days after:1. The balance occurs if it happens after the first day of classes of a payment period; or 2. The first day of classes of a payment period if the balance occurs on or before that day. Cause: This instance of noncompliance was due to an oversight in the Institution’s monitoring and disbursement process. Effect: Failure to timely disburse Title IV credit balances results in students not receiving financial aid funds when needed for educational and living expenses, potentially creating financial hardship. Questioned Costs: $0 –– Non-monetary compliance finding. Recommendation: The Institution should strengthen its monitoring and internal control procedures to ensure that Title IV credit balances are consistently identified and disbursed within the required timeframe. View of Responsible Officials: The Institution concurs with the finding. See corrective action plan.

Corrective Action Plan

Actions Taken / Planned The institution recognizes the importance of timely processing of Title IV credit balances and refunds. To address the deficiencies identified: 1. Short-Term Action (Current Practice): Effective immediately, all staff are required to submit for processing refunds within 24 hours of identifying a credit balance. Staff will also promptly correct any errors discovered during the reconciliation process. o Monitoring: Supervisors will conduct weekly reviews to ensure compliance with this 24-hour policy. o Training: Refresher training on Title IV credit balance processing has been provided to all relevant staff as of September 2025. o Instead of one ‘check run’ per week, numerous ‘check runs’ may be necessary to ensure 14 day window is met. 2. Long-Term Action (System Integration and Automation): The institution is actively working to integrate QuickBooks into our Student Information System (SIS) to automate Title IV and refund documentation. o This integration will streamline the reconciliation process, reduce manual errors, and ensure consistent, timely processing of refunds. o Projected Completion Date: Implementation and full automation are expected to be completed within 9–12 months, with a target date of September 2026. Expected Outcome: These measures will ensure timely and accurate processing of Title IV credit balances, improve compliance, and reduce the risk of future findings.

Categories

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring

Other Findings in this Audit

  • 1157282 2024-001
    Material Weakness Repeat
  • 1157284 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $9.04M
84.063 Federal Pell Grant Program $4.74M
84.007 Federal Supplemental Educational Opportunity Grants $131,342