Finding 1175475 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-26
Audit: 389269
Organization: Knox College (IL)
Auditor: RSM US LLP

AI Summary

  • Core Issue: The College failed to pay Title IV credit balances to students within the required 14-day timeframe.
  • Impacted Requirements: Noncompliance with 34 CFR 668.164(h)(2) and lack of documented controls under Uniform Grant Guidance.
  • Recommended Follow-Up: Review and update processes for timely refunds to ensure compliance and prevent future funding loss.

Finding Text

2025-002—Disbursements to or on Behalf of Students (Credit Balances) U.S. Department of Education Student Financial Assistance Programs Cluster (Direct) Federal Direct Loan Program (84.268) Federal Pell Grant Program (84.063) Federal Work Study (84.033) Federal Award Year: 2024-2025 Repeat Finding: Yes Criteria The Code of Federal Regulations (34 CFR 668.164(h)(2)) requires that Title IV credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition The College did not pay the Title IV credit balances to the students directly within the required timeline noted above. Out of the 40 students tested, we noted 2 students (5%) whose credit balances were not paid directly to the students within the required timeframe noted above. The incorrect timing did not have an effect on the total award given to students (timing only). The College did not have formally documented controls related to the process associated with disbursements to or on behalf of students (credit balances), which is required under Uniform Grant Guidance. Cause A refund to the students were required to be made within the required timeframe and were done outside the required timeframe. Effect Noncompliance with federal regulations could result in the loss of future federal funding. Questioned costs There were no questioned costs with respect to this finding. Context We tested 40 students who had a credit balance of Title IV funds during the fiscal year ended June 30, 2025. For each student tested, management provided documentation from their student information system, showing the when the student was in a credit balance, and when the credit balance was disbursed to the student. Out of the 40 students tested, we noted 2 students (5%) whose credit balances were not timely refunded. Recommendation We recommend the College review current processes and implement updated processes and controls for timely student credit balance refunds. Views of responsible officials Management agrees with this finding. See corrective action plan.

Corrective Action Plan

Identifying Number: 2025-002 Finding: Disbursements to or on Behalf of Students (Credit Balances) The College did not pay the Title IV credit balances to the students directly within the required timeline noted above. Out of the 40 students tested, we noted 2 students (5%) whose credit balances were not paid directly to the students within the required timeframe noted above. The incorrect timing did not have an effect on the total award given to students (timing only). The College did not have formally documented controls related to the process associated with disbursements to or on behalf of students (credit balances), which is required under Uniform Grant Guidance. Corrective Actions Taken or Planned: Knox College has implemented the following corrective measures to ensure compliance with federal credit balance requirements: 1. Automated Monitoring: A system-generated report (Aging Report) of all student credit balances is now produced twice per week from the Jenzabar J1 student information system. 2. Formal Workflow: The AVP of Student Financial Services (SFS) will review the Student Accounts Aging Report. Student Financial Services Advisors will review each of their student accounts that have a credit balance within 24 hours. If the student has a credit balance and has receive Title IV aid during the academic year, the advisor will review if the credit balance is derived by Title IV. A standardized credit balance processing schedule has been established, ensuring that credit balances are reviewed and released within 14 days of disbursement. Role Clarification: Responsibilities are now clearly defined: • SFS confirms refund eligibility. • Business Office processes refunds through Bill.com and posts to the student account. Staff Training: Relevant staff received training on: • Title IV credit balance requirements • Handling of student/parent authorizations • Timely return of unclaimed funds Documentation Controls: All credit balance disbursement and return transactions are documented and retained as part of the official audit record. Person Responsible: Leigh Brinson, Assistant Vice President of Student Financial Services, ltbrinson@knox.edu Anticipated Completion Date: November 10, 2025

Categories

Student Financial Aid

Other Findings in this Audit

  • 1175466 2025-001
    Material Weakness Repeat
  • 1175467 2025-001
    Material Weakness Repeat
  • 1175468 2025-001
    Material Weakness Repeat
  • 1175469 2025-001
    Material Weakness Repeat
  • 1175470 2025-001
    Material Weakness Repeat
  • 1175471 2025-002
    Material Weakness Repeat
  • 1175472 2025-002
    Material Weakness Repeat
  • 1175473 2025-002
    Material Weakness Repeat
  • 1175474 2025-002
    Material Weakness Repeat
  • 1175476 2025-003
    Material Weakness Repeat
  • 1175477 2025-003
    Material Weakness Repeat
  • 1175478 2025-003
    Material Weakness Repeat
  • 1175479 2025-003
    Material Weakness Repeat
  • 1175480 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.12M
84.063 FEDERAL PELL GRANT PROGRAM $2.29M
84.042 TRIO STUDENT SUPPORT SERVICES $400,941
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $363,098
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $339,728
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $195,183
84.033 FEDERAL WORK-STUDY PROGRAM $183,641
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $97,240
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $57,599