Finding 1172786 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-06

AI Summary

  • Core Issue: Nine out of sixty Return to Title IV calculations were processed late, exceeding the 45-day requirement after student withdrawal.
  • Impacted Requirements: Compliance with 34 CFR section 668.173(b) regarding timely returns of Title IV funds.
  • Recommended Follow-Up: Enhance internal controls and monitoring procedures to ensure timely processing of Return to Title IV funds.

Finding Text

Special Test and Provisions – Return to Title IV Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Identification Numbers: P007A240491, P033A240491, P063P241158, P268K251158 Award Year: 2024-2025 Criteria 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date 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 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. Condition Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance – Nine of the sixty Return to Title IV calculations were returned later than 45 days after the institution determined the student withdrew. Questioned Costs There are no questioned costs associated with this finding. All funds were returned, however, not within the 45-day requirement. Context We tested a non-statistical sample of sixty Return to Title IV calculations of a total of 683 calculations performed by the District during the year ended June 30, 2025. Effect Without proper monitoring of the timing of student withdrawals and calculations of Return to Title IV, the District risks noncompliance with the above referenced criteria. Cause The District’s internal controls did not have adequate internal controls and monitoring procedures in place to ensure timely identification and processing of Return of Title IV funds. This resulted in instances in which the return of funds was not completed within the required time frame. Repeat Finding (Yes or No) No. Recommendation The District should implement procedures and improve controls over the review of the calculations to ensure funds are returned in a timely manner.

Corrective Action Plan

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were temporarily assigned to manage these responsibilities during the transition period, which contributed to delays in returning funds within the required regulatory timeframe. A comprehensive review of all R2T4 calculations completed during the 2024–2025 aid year determined that records processed prior to mid-November 2024 had over awarded funds returned within the applicable 45- and 30-day regulatory timeframes. This timeframe aligns with the period when the responsible staff members announced their retirements. To resolve this matter and prevent recurrence, the District has implemented the following corrective measures. Targeted R2T4 Training: Staff responsible for Return to Title IV (R2T4) processing and disbursement reversals are in the process of completing the National Association of Student Financial Aid Administrators (NASFAA) R2T4 credential training. This certification will ensure staff possess consistent, up-to-date knowledge of federal requirements around the R2T4 process to include the timelines required to return over-awarded funds to the department. Automated Monitoring Report: A recurring monitoring report has been established to identify students with pending Returns of Title IV (R2T4) funds. The report automatically flags cases exceeding 30 days and, for students who withdrew prior to the start of the term, those exceeding 20 days. Department managers will generate and review this report on a weekly basis to ensure timely compliance with federal return requirements. In instances where pending returns are identified as being past the alert threshold, Financial Aid management will promptly coordinate with Fiscal Services to expedite the return of funds and document resolution actions. Cross-Training for Continuity of Operations: Ongoing cross-training has been implemented among Financial Aid staff to ensure sufficient coverage during vacations, extended leaves, or unexpected absences. At least two designated staff members will be fully trained and authorized to perform R2T4 calculations and return processing to prevent delays in compliance during personnel transitions. These measures strengthen accountability, monitoring, and collaboration between the Financial Aid and Fiscal Services departments to ensure full compliance with federal cash management and return regulations.

Categories

Subrecipient Monitoring Student Financial Aid Significant Deficiency

Other Findings in this Audit

  • 1172773 2025-001
    Material Weakness Repeat
  • 1172774 2025-001
    Material Weakness Repeat
  • 1172775 2025-001
    Material Weakness Repeat
  • 1172776 2025-001
    Material Weakness Repeat
  • 1172777 2025-001
    Material Weakness Repeat
  • 1172778 2025-001
    Material Weakness Repeat
  • 1172779 2025-001
    Material Weakness Repeat
  • 1172780 2025-002
    Material Weakness Repeat
  • 1172781 2025-002
    Material Weakness Repeat
  • 1172782 2025-002
    Material Weakness Repeat
  • 1172783 2025-002
    Material Weakness Repeat
  • 1172784 2025-002
    Material Weakness Repeat
  • 1172785 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $2.70M
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $1.54M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $1.43M
84.047 TRIO UPWARD BOUND $311,637
84.042 TRIO STUDENT SUPPORT SERVICES $264,559
10.558 CHILD AND ADULT CARE FOOD PROGRAM $138,222
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $129,550
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $116,732
93.600 HEAD START $112,622
84.031 HIGHER EDUCATION INSTITUTIONAL AID $98,459
84.063 FEDERAL PELL GRANT PROGRAM $68,905
84.016 UNDERGRADUATE INTERNATIONAL STUDIES AND FOREIGN LANGUAGE PROGRAMS $44,311
84.033 FEDERAL WORK-STUDY PROGRAM $42,079
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $37,710
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $35,421
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $25,375
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $13,800
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $12,084
64.027 POST-9/11 VETERANS EDUCATIONAL ASSISTANCE $9,792
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $389