Finding Text
Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 34 CFR 668.164(I), when students are issued a check for aid earned in excess of tuition and fees collected by the School District, students have 240 days to cash the check. Any uncashed funds after 240 days must be returned to the Department of Education and cannot be escheated to the State. Condition - The institution's policy maintains that any uncashed check must be escheated to the State of Colorado after the financial statement year end to the Great Colorado Payback program and does not include a carve out for uncashed Title IV aid checks. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - No outstanding disbursements beyond 240 days were identified during the audit period and no funds were escheated to the state during the period under audit. Identification of How Questioned Costs Were Computed - N/A Context - The School District maintains a written policy that directs unclaimed Title IV funds to be returned to the State of Colorado through the Great Colorado Payback program, rather than to the U.S. Department of Education as required under federal regulations. During fiscal year 2024, there were no uncashed checks after the 240 time period and therefore, no funds were reverted to the State of Colorado. Cause and Effect - The School District was unaware of the specific regulatory requirement and had not updated its disbursement policy to reflect current federal guidelines. Although no disbursements were made in violation during the audit period, the institution’s policy is noncompliant with Uniform Guidance. Recommendation - We recommend the institution revise its disbursement policy to align with the requirement that all uncashed Title IV funds be reverted to the Department of Education. Staff responsible for financial aid disbursements should be trained on federal timing requirements. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is revising its disbursement policy to ensure all uncashed Title IV funds are returned to the Department of Education in accordance with federal requirements. Staff responsible for financial aid disbursements are receiving training on federal timing and return-of-funds requirements to ensure accurate and compliant processing moving forward.