Finding 1169663 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-20

AI Summary

  • Core Issue: Late returns of Title IV funds and NSLDS reporting errors were identified, violating federal regulations.
  • Impacted Requirements: Funds must be returned within 45 days of withdrawal; NSLDS updates must occur within 60 days.
  • Recommended Follow-Up: Implement additional controls in the Student Financial Aid and Registrar’s Offices to improve review processes for timely refunds and reporting.

Finding Text

2025-002: Student Financial Audit Cluster - Special Tests: Return of Title IV Funds and NSLDS Reporting (Significant Deficiency; Noncompliance) Criteria: Per 34 CFR 668.173(b), returns of Title IV funds are required to be deposited or transferred into the bank account maintained under 34 CFR 668.163 or via electronic fund transfers initiated to the U.S. Department of Education as soon as possible, but no later than 45 days after the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined that the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Per 34 CFR 685.309(b), “Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary.” Condition/context: Of the 15 students selected to test both the proper return of Title IV funds and National Student Loan Data System (NSLDS) reporting, we noted the following errors: • Two instances where the funds were not returned within the 45-day period allowed; and • One instance in which the student was not reported within 60 days of the date of determination. Cause: Human error. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid Office and Registrar’s Office should consider additional controls to ensure the proper review and identification of withdrawals for timeliness of refund payments and reporting to NSLDS. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.

Corrective Action Plan

2025-002: Student Financial Audit Cluster - Special Tests: Return of T itle IV Funds and NSLDS Reporting Anticipated completion date: done - June 18, 2025 Contact person: Brandi Payne Cervera Corrective actions: The two late aid returns were made under the following circumstances. Student's effective date of the withdrawal was March 25, 2025. However, the withdrawal was not processed in our Colleague system until April 9, 2025. The backdated effective date of the withdrawal in Colleague did not appear on our enrollment activity report that is used to identify complete withdrawals because this report is run weekly using a defined date range. As a result, the student's withdrawal was not identified in a timely manner. The withdrawal was identified by our Assistant Director upon her review of students with all non-passing grades at the end of the semester prior to the audit testing (see existing procedure/internal control below). The return-of-funds was processed as soon as the withdrawal was discovered, but it was out of the 45-day required timeframe. We have implemented a new procedure, as follows. New procedure (backdated withdrawal): The Registrar's Office will immediately notify Financial Aid of any withdrawals received by the Registrar's Office that require a backdated effective date in Colleague to ensure that we are returning funds within the required timeframe. The Financial Aid Director, Assistant Director of Financial Aid, and the Registrar met and developed this new procedure. The procedure was implemented on June 18, 2025. An institution must certify enrollment information to the National Student Loan Data System (NSLDS) every 60 days. Because of the issue with the backdated effective date of the withdrawal described above, the enrollment reporting for this student was made outside of the 60-day reporting window. I request the removal of the NSLDS reporting deficiency since the late processing of the student's withdrawal and return-of-funds was the root cause of the late NSLDS reporting, and there were no other enrollment reporting issues. The second late return was due to human error. After a R2T4 calculation has been performed, there is an "Update Student Aid" button on the ROFC screen in Colleague that must be manually marked "yes" in order for the return of- funds to post to the student's account. This step was missed for one student which caused the late return-of-funds outside of the required 45-day timeframe. New procedure (human error): Assistant Director has put a standing item on her calendar to review RT24's every Wednesday with a notation to check the "Update Student Aid" box in Colleague so that the return will occur. The Assistant Director will also check the list of withdrawals after each weekly aid transmittal to make sure the aid returns have all posted to the student accounts as expected. This procedure was put into place on June 18, 2025. Existing Procedure/Internal Control: We can say with certainty that out of the 165 withdrawals for the 2024/2025 award year, the two students identified in the audit were the only two late returns. The Assistant Director of Financial Aid reviews all students with non-passing grades at the end of each semester to identify unofficial withdrawals and to ensure that all returns were made appropriately and that no R2T4 calculations were missed. Potential issues are identified through this end-of-semester review. This is how the issue with the backdated withdrawal date described above was discovered. She will continue this effective internal control process each semester which will confirm that our new procedures are working as intended.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1169661 2025-001
    Material Weakness Repeat
  • 1169662 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $7.23M
84.268 FEDERAL DIRECT STUDENT LOANS $4.85M
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $378,753
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $307,084
84.425 EDUCATION STABILIZATION FUND $166,754
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $161,941
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $160,000
47.076 EDUCATION AND HUMAN RESOURCES $97,539
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $43,934
10.664 COOPERATIVE FORESTRY ASSISTANCE $38,580
84.033 FEDERAL WORK-STUDY PROGRAM $33,517
17.259 WIA YOUTH ACTIVITIES $18,811
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $17,280
20.200 HIGHWAY RESEARCH AND DEVELOPMENT PROGRAM $4,010