Finding 1168713 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-11
Audit: 380724
Organization: Montreat College (NC)
Auditor: SIKICH CPA LLC

AI Summary

  • Core Issue: The College inaccurately calculated refunds for 2 out of 9 students, failing to notify one student about a post-withdrawal disbursement of Federal Direct Loans.
  • Impacted Requirements: Non-compliance with 34 CFR 668.22 regarding the return of Title IV funds and timely notification of post-withdrawal disbursements.
  • Recommended Follow-Up: The College should enhance training on Title IV requirements and improve policies to ensure timely notifications for post-withdrawal disbursements.

Finding Text

2025-003 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Criteria: 34 CFR 668.22 (a)(1) states “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 in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b). (2) For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the – (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew” An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22). Condition: The College did not accurately complete refund calculations for 2 out of 9 students (22.2%) tested that both required post-withdrawal disbursements. For one of these students, the College did not notify the student of the post-withdrawal disbursement of Federal Direct Loans before it was applied to the student’s account. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-007. Statistical sampling was not used in making sample selections. Questioned Costs: $319 Effect: Miscalculations in the Return of Title IV funds calculations results in incorrect amounts returned by the College or incorrect amounts disbursed to students in post-withdrawal disbursements. For the post-withdrawal disbursement notification, without notifying the student, direct loans may be applied to the student’s account that they are not aware of or would have wanted to decline the disbursement if they were notified. Recommendation: For the incorrect refund calculations, we recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented accurately to return unearned aid or disburse earned aid in post-withdrawal disbursements. For not notifying the student of the post-withdrawal disburrsement, we recommend the College reviews their policies and procedures written notification is timely provided to the student for post-withdrawal disbursements of Federal Direct Loans to allow them to decline, if they choose to do so. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Condition Found The Organization did not accurately complete refund calculations for 2 out of 9 students (22.2%) tested that both required post-withdrawal disbursements. For one of these students, the College did not notify the student of the post-withdrawal disbursement of Federal Direct Loans before it was applied to the student’s account. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-007. Corrective Action Plan To ensure accuracy and compliance going forward, the Student Financial Services (SFS) team will implement the following corrective actions: • Establish a double-layer review process for all post-withdrawal disbursements. • Each PWD calculation and notification will undergo an initial entry review by the staff member completing the R2T4 and a secondary accuracy check by a separate staff member prior to submission and disbursement. • This layered review is intended to catch and correct data entry errors prior to finalization. Responsible Person for Corrective Action Plan Deb Beck Implementation Date of Corrective Action Plan 10/1/2025

Categories

Student Financial Aid

Other Findings in this Audit

  • 1168708 2025-003
    Material Weakness Repeat
  • 1168709 2025-003
    Material Weakness Repeat
  • 1168710 2025-003
    Material Weakness Repeat
  • 1168711 2025-003
    Material Weakness Repeat
  • 1168712 2025-002
    Material Weakness Repeat
  • 1168714 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.20M
84.063 FEDERAL PELL GRANT PROGRAM $2.16M
12.902 INFORMATION SECURITY GRANTS $157,801
97.037 HELENE RECOVERY $92,982
84.033 FEDERAL WORK-STUDY PROGRAM $91,575
12.905 CYBERSECURITY CORE CURRICULUM $69,216
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $62,837
84.184 SAFE AND DRUG-FREE SCHOOLS AND COMMUNITIES_NATIONAL PROGRAMS $21,892
21.019 CORONAVIRUS RELIEF FUND $7,344