Finding 1173578 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-13
Audit: 387298
Organization: Missouri Baptist University (MO)

AI Summary

  • Core Issue: The University failed to return Title IV funds to the U.S. Department of Education and student accounts within required timeframes for withdrawn students.
  • Impacted Requirements: Regulations mandate returns within 45 days for withdrawn students and 30 days for students who never attended, which were not met in multiple cases.
  • Recommended Follow-Up: The University should assess and improve its controls for monitoring Title IV fund returns to ensure timely compliance.

Finding Text

Information on the Federal Program: Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program, U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement: Special Tests and Provisions - Return of Title IV Funds (34 CFR 668.22) Condition: Federal regulations provide that the University is responsible for returning funds to ED and student accounts within 45 days of the University becoming aware the student has withdrawn, or within 30 days for students that never began attendance. The University’s internal control system did not prevent certain late disbursements of return of funds. Questioned Costs: None Context: Out of a population of 40 withdrawn students requiring return of Title IV funds, a sample of 5 withdrawn students were selected for testing. All 5 of the returns were not returned to ED or the student within the required time frame. Of these students, 4 of the 5 returns were not returned to ED within the 45 day period. Additionally, 2 of the 5 returns were not returned to ED or the student within the 30 day period for students that never began attendance. Our sample was not, and was not intended to be, statistically valid. Effect: The University may not be able to timely detect when return of funds are required for students who have withdrawn or never began attendance. This could result in late disbursements to ED and the student accounts for Direct Loan and Pell recipients. Cause: The University's processes did not ensure return of Title IV funds were completed accurately and timely. Identification as a Repeat Finding, if Applicable: 2024-001 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to properly capture return of Title IV funds on a timely basis. Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Corrective Action Plan

Reference Number 2025-02 Return of Title IV Funds (R2T4) Since the 2025 audit, there have been significant improvements in oversight and process management for R2T4 calculations. A leadership transition occurred, and the Associate Director - bringing over 30 years of higher education experience, including prior service as a Financial Aid Director - has assumed responsibility for R2T4 calculations for the 2026-27 academic year. To ensure compliance and accuracy, the Associate Director completed a Department of Education training refresher on R2T4 calculations during Spring 2025. Additionally, the interim Financial Aid Director implemented a structured plan to monitor all student withdrawals and guarantee timely completion of calculations. For Fall 2025, the process has remained on schedule. A two-tier accountability system is in place: the Associate Director manages calculations, and the Director provides immediate support if any delays occur. A comprehensive tracking spreadsheet was developed to record each withdrawal, including the withdrawal date, federal aid status, and the date the R2T4 calculation was completed. This tool ensures real-time monitoring and accuracy. The daily withdrawal report introduced after the 2024 audit continues to be a valuable resource; however, the combination of this report with the new tracking system and dual oversight has proven to be the cornerstone of compliance. All calculations are current, accurate, and completed within required timelines. Based on these improvements, we do not anticipate any findings in the upcoming audit.

Categories

Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1173577 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $16.49M
84.063 FEDERAL PELL GRANT PROGRAM $4.01M
84.033 FEDERAL WORK-STUDY PROGRAM $225,465
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $177,696
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $70,519