Finding 1168225 (2024-005)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2026-01-07
Audit: 380015
Organization: Heritage University (WA)

AI Summary

  • Core Issue: There are significant deficiencies in internal controls regarding the Return of Title IV Funds (R2T4) calculations, leading to incorrect financial aid determinations for students who withdrew.
  • Impacted Requirements: Compliance with 34 CFR 668.22 was not met, as the University failed to maintain proper documentation for withdrawal dates, affecting aid calculations and potentially resulting in unreturned funds.
  • Recommended Follow-Up: The University should enhance policies to ensure all withdrawals are documented accurately and implement controls for timely R2T4 calculations to prevent future discrepancies.

Finding Text

Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P232403, P379T242403, P268K242403, P007A234364 Award Year: 2023-24, 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 6 official and 2 unofficial withdrawals from a population of 41 total withdrawals. Two students tested were mistakenly processed as official withdrawals, however the University was unable to support the withdrawal dates. As such, the 50% rate should have been used for the R2T4 calculation. This would have resulted in one student earning more aid than originally calculated. For the second student this would have resulted in funds needing to be returned. For one sample selection the R2T4 was not completed until approximately 8 months after the student had notified the University of their withdrawal. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – Yes, 2023-009 Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. We also recommend a control be put in place to ensure the calculations are performed timely. Views of responsible officials and planned corrective actions – As a response to concerns about disruptions in processes and the turnover of key staff in several departments, the Enrollment Alliance group that includes director-level staff in Admissions, the Registrar, Financial Aid, Advising, Bursar, and IT began meeting under the facilitation of the VP of Student Affairs on January 7, 2025. This group has helped to guide the Registrar's Office in the development and workflow structure of an electronic withdrawal form that must be routed through several required offices, including Financial Aid, to ensure that processes including R2T4 calculations are completed and correct for each student who withdrawals during the semester. This structure is now in place.

Corrective Action Plan

Planned corrective actions: As a response to concerns about disruptions in processes and the turnover of key staff in several departments, the Enrollment Alliance group that includes director-level staff in Admissions, the Registrar, Financial Aid, Advising, Bursar, and IT began meeting under the facilitation of the VP of Student Affairs on January 7, 2025. This group has helped to guide the Registrar's Office in the development and workflow structure of an electronic withdrawal form that must be routed through several required offices, including Financial Aid, to ensure that processes including R2T4 calculations are completed for each student who withdrawals during the semester. This structure is now in place. Name of Responsible Party: 1. Nancy Benavides,Financial Aid Director 2. J.T. Menard, Registrar 3. Ivan Banks, Interim Provost 4. Corey Hodge, VP for Student Affairs 5. Joanne Fernandez, Controller 6. Marla Withers, Assistant Controller 7. Sagrario Armenta Jimenez, CFO 8. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

Categories

Student Financial Aid Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 1168215 2024-003
    Material Weakness Repeat
  • 1168216 2024-005
    Material Weakness Repeat
  • 1168217 2024-007
    Material Weakness Repeat
  • 1168218 2024-005
    Material Weakness Repeat
  • 1168219 2024-005
    Material Weakness Repeat
  • 1168220 2024-002
    Material Weakness Repeat
  • 1168221 2024-002
    Material Weakness Repeat
  • 1168222 2024-003
    Material Weakness Repeat
  • 1168223 2024-004
    Material Weakness Repeat
  • 1168224 2024-004
    Material Weakness Repeat
  • 1168226 2024-006
    Material Weakness Repeat
  • 1168227 2024-007
    Material Weakness Repeat
  • 1168228 2024-008
    Material Weakness Repeat
  • 1168229 2024-008
    Material Weakness Repeat
  • 1168230 2024-009
    Material Weakness Repeat
  • 1168231 2024-009
    Material Weakness Repeat
  • 1168232 2024-009
    Material Weakness Repeat
  • 1168233 2024-009
    Material Weakness Repeat
  • 1168234 2024-009
    Material Weakness Repeat
  • 1168235 2024-009
    Material Weakness Repeat
  • 1168236 2024-009
    Material Weakness Repeat
  • 1168237 2024-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $2.78M
84.268 FEDERAL DIRECT STUDENT LOANS $2.73M
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES $1.03M
84.425 EDUCATION STABILIZATION FUND $557,563
84.141 MIGRANT EDUCATION HIGH SCHOOL EQUIVALENCY PROGRAM $524,057
84.031 HIGHER EDUCATION INSTITUTIONAL AID $475,567
84.149 MIGRANT EDUCATION COLLEGE ASSISTANCE MIGRANT PROGRAM $336,066
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $296,420
84.042 TRIO STUDENT SUPPORT SERVICES $275,291
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $118,077
84.033 FEDERAL WORK-STUDY PROGRAM $67,988
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $52,110
10.558 CHILD AND ADULT CARE FOOD PROGRAM $39,983
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $35,127
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $26,409
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $17,084
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $15,739
43.001 SCIENCE $12,850
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $11,788
45.024 PROMOTION OF THE ARTS GRANTS TO ORGANIZATIONS AND INDIVIDUALS $6,067
47.074 BIOLOGICAL SCIENCES $1,204
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $0