Finding 1163405 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-03
Audit: 372939
Organization: Texas Wesleyan University (TX)

AI Summary

  • Core Issue: The University incorrectly returned funds to the U.S. Department of Education due to flaws in internal controls regarding the Return of Title IV Funds (R2T4) process.
  • Impacted Requirements: Compliance with federal regulations for accurate fund returns and proper documentation for post-withdrawal disbursements.
  • Recommended Follow-Up: Update internal controls to ensure accurate R2T4 calculations and maintain proper documentation for all student notifications.

Finding Text

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the amounts to be returned to the U.S. Department of Education were correct and notification of a post-withdrawal disbursement could not be located. Questioned costs - $0 Context – Out of the population of 122 students who withdrew, 23 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The R2T4 calculations for 6 students in the sample were correct, but the amount returned to COD was based on the net loan amount rather than the gross amount. The University returned more funds to the COD than was required. Additionally, one student was eligible for a post-withdrawal disbursement, but documentation that the student had been notified was not able to be obtained. Effect – The amount originally returned was incorrect. Cause – The University’s internal controls did not ensure proper inputting of information to return funds. Identification as a repeat finding, if applicable – 2024-001 and 2023-001 Recommendation – The University should update their controls to ensure the R2T4 inputs for the return of funds are correct. Views of responsible officials and planned corrective actions – The University concurs that errors occurred in posting the loan amount to be returned for six (6) Return of Title IV (R2T4) transactions identified during the audit review resulting in a total return of funds for the six (6) students which was $757.56 more than required. Specifically, the actual calculations were completed accurately, but each student’s loan amount was adjusted for loan origination fees when they should not have been adjusted. All updates to records were made for those that required updating. The University also acknowledges that documentation for one student that was required for a post-withdrawal disbursement notification cannot be located. Although the calculation and determination were completed, the supporting documentation of that notification was not properly retained in the student’s record.

Corrective Action Plan

Corrective Actions: To strengthen internal controls and ensure full compliance with federal regulations, the University has implemented the following measures: 1. Secondary Review Implementation: The University has contracted with an external consultant to serve as a secondary reviewer. In the interim, an internal staff member is receiving comprehensive R2T4 training and will complete the NASFAA Return of Title IV Funds Certification Program in March 2026. Upon completion of the NASFAA Program coursework, the staff member will complete an examination on or before May 31, 2026. Once certification is achieved and the University has full confidence in the internal review process, the secondary review function will transition from the external consultant to an in-house process. 2. Documentation Retention Enhancement: The University has reinforced procedures, including those document retention protocols, by adding this as an additional checklist item on the R2T4 checklist, to ensure that all post-withdrawal disbursement notifications are properly retained in each student’s financial aid record, either electronically or within the designated document management system. The checklist is meant to be a roadmap for the reviewer to ensure each step is completed in the calculation process and that documentation is retained for post-withdrawal disbursement. 3. Staff Training: All financial aid staff involved in the R2T4 process have received updated training on the correct handling of loan returns and post-withdrawal notifications in accordance with 34 CFR 668.22 and current FSA Handbook guidance. Staff involved with R2T4 administration include the Financial Aid Business Analyst and a Financial Aid Advisor. Both team members have completed either official NASFAA or FSA training. The Financial Aid Advisor will be completing the NASFAA Certificate training on R2T4. Additionally, the Assistant Director will also complete the program at the same time, increasing the depth of knowledge for the team around this topic. Responsible Official: Doug Cleary, Director of Financial Aid Estimated Completion Date: May 31, 2026

Categories

Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1163401 2025-001
    Material Weakness Repeat
  • 1163402 2025-001
    Material Weakness Repeat
  • 1163403 2025-001
    Material Weakness Repeat
  • 1163404 2025-001
    Material Weakness Repeat
  • 1163406 2025-002
    Material Weakness Repeat
  • 1163407 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $28.58M
84.063 FEDERAL PELL GRANT PROGRAM $6.81M
84.047 TRIO UPWARD BOUND $1.18M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $758,100
84.031 HIGHER EDUCATION INSTITUTIONAL AID $439,894
84.033 FEDERAL WORK-STUDY PROGRAM $324,027
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $305,706
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $66,923
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $11,316
45.310 GRANTS TO STATES $1,104