Finding 1175409 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-25

AI Summary

  • Core Issue: The District failed to accurately calculate and timely return Title IV funds for two students, indicating a significant deficiency in internal controls.
  • Impacted Requirements: Noncompliance with 34 CFR 668.22(a), 34 CFR 668.22(e), and 34 CFR 668.173(b) regarding the Return to Title IV funds process.
  • Recommended Follow-Up: Strengthen internal controls to ensure accurate calculations and timely returns of Title IV funds to avoid future compliance risks.

Finding Text

Criteria 34 CFR 668.22(a) and 34 CFR 668.22(e) When a recipient of Title IV 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 aid earned by the student as of the student’s withdrawal date. The amount of Title IV assistance that is earned by the student is calculated by determining the percentage of aid earned by the student and applying the percentage to the total amount of Title IV assistance that was disbursed and that could have been disbursed to the student. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, or on his or her behalf, as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. 34 CFR 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (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. Condition Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance – For two of sixty-eight students tested, we noted deviations from the District’s designed procedures and controls which resulted in the following discrepancies:  The District inaccurately calculated the Return to Title IV funds for one out of sixty-eight students and did not return the institution’s portion of the required return in a timely manner.  The District returned the incorrect amount required per the Return to Title IV calculation for one out of sixty-eight students. Questioned Costs There are no questioned costs associated with the condition identified. Context There were 1,110 Return to Title IV calculations performed during the year ended June 30, 2025. Effect Without proper monitoring of Return of Title IV calculations and amounts returned, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls were not sufficient to prevent erroneous information utilized in the calculations and to ensure funds are returned in a timely manner. Repeat Finding (Yes or No) No. Recommendation The District should strengthen internal controls over the review of Return of Title IV calculations to ensure that calculations are accurate and funds are returned in a timely manner.

Corrective Action Plan

The Office of Financial Aid is currently strengthening the Return to Title IV (R2T4) process by formalizing written procedures and integrating industry best practices. As part of this effort, we are implementing a quality control system whereby a second team member reviews each file to ensure the accuracy of calculations, the completion of necessary pullbacks or billings, and timely communication with students. Additionally, we are enhancing our Title IV reconciliation process to serve as an added layer of oversight, verifying that award data in our student information system (Banner) aligns with records in the Common Origination and Disbursement (COD) system.

Categories

Student Financial Aid Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1175404 2025-001
    Material Weakness Repeat
  • 1175405 2025-001
    Material Weakness Repeat
  • 1175406 2025-001
    Material Weakness Repeat
  • 1175407 2025-001
    Material Weakness Repeat
  • 1175408 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $2.90M
84.268 FEDERAL DIRECT STUDENT LOANS $2.27M
84.425 EDUCATION STABILIZATION FUND $1.67M
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $1.13M
84.033 FEDERAL WORK-STUDY PROGRAM $829,145
84.047 TRIO UPWARD BOUND $598,853
84.031 HIGHER EDUCATION INSTITUTIONAL AID $448,230
84.042 TRIO STUDENT SUPPORT SERVICES $407,740
84.335 CHILD CARE ACCESS MEANS PARENTS IN SCHOOL $390,150
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $248,395
84.120 MINORITY SCIENCE AND ENGINEERING IMPROVEMENT $241,860
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $221,971
47.074 BIOLOGICAL SCIENCES $131,795
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $99,387
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $89,268
43.001 SCIENCE $77,254
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $61,582
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $55,561
84.063 FEDERAL PELL GRANT PROGRAM $52,980
10.558 CHILD AND ADULT CARE FOOD PROGRAM $49,077
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $33,511
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $31,493
84.044 TRIO TALENT SEARCH $24,003
84.015 NATIONAL RESOURCE CENTERS PROGRAM FOR FOREIGN LANGUAGE AND AREA STUDIES OR FOREIGN LANGUAGE AND INTERNATIONAL STUDIES PROGRAM AND FOREIGN LANGUAGE AND AREA STUDIES FELLOWSHIP PROGRAM $10,857
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $8,489
77.008 U.S. NUCLEAR REGULATORY COMMISSION SCHOLARSHIP AND FELLOWSHIP PROGRAM $6,355
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $6,330
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $5,004
10.665 SCHOOLS AND ROADS - GRANTS TO STATES $4,582
81.121 NUCLEAR ENERGY RESEARCH, DEVELOPMENT AND DEMONSTRATION $1,554