Finding 1175619 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-26
Audit: 389454
Organization: National University (CA)

AI Summary

  • Core Issue: The University failed to complete required R2T4 calculations for 5 students and did not return Title IV funds for 4 students within the 45-day deadline.
  • Impacted Requirements: Compliance with 34 CFR 668.22 regarding timely R2T4 calculations and fund returns is not being met, indicating a significant deficiency in internal controls.
  • Recommended Follow-Up: The University should enhance procedures for R2T4 calculations and ensure timely returns of Title IV funds to prevent future compliance issues.

Finding Text

Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Federal Award Identification Number and Year: Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan 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 grant or loan assistance that the student earned as of the student’s withdrawal date. An institution must also return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew in accordance with 34 CFR 668.22(j). Condition: During our testing, we noted that for 5 out of 60 students, a R2T4 calculation wasn’t completed when a calculation should have been performed. In addition, we noted that 4 out of 60 students did not have their R2T4 funds returned within 45 days of the school determining that the student withdrew. Questioned Costs: None over $25,000 Context: During our testing, we noted that although the University had procedures in place to verify that all students who qualify for R2T4 calculations have calculations performed and that Title IV funds are returned timely, those procedures were not always effective and resulted in errors. Cause: The University's processes and controls did not ensure that R2T4 calculations were properly performed accurately and that Title IV funds were returned timely. Effect: Title IV funds were not returned properly and timely to the federal government. Repeat Finding: Yes. 2024-001 Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Views of Responsible Official: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the importance of ensuring that the return of Title IV funds (R2T4) calculation is performed both timely and accurately. The University has taken significant steps to improve its compliance with R2T4 requirements. These efforts have yielded improved results with the late return error rate decreasing year over year from 13% to 7%. The University will continue to monitor staffing levels and workload to ensure that staffing aligns with timeline requirements. The University’s Processing team will lead focused R2T4 training on topics related to areas of noncompliance. Additional topics will be identified throughout the year as trends are identified in the Quality Assurance Audit process. The following steps will be taken immediately to address finding 2025-001. - The Processing team will continue to conduct subject matter training monthly, prioritized as follows: o Post Withdrawal Disbursements (PWD) identification o Post Withdrawal Disbursement timeline requirements - A new weekly review will be implemented by quality assurance outside of the review completed by R2T4 leadership to test if processing specialists are accurately determining if an R2T4 is required and if a refund is needed for a withdrawn student. Results will be used to coach staff members as needed. The University’s Quality Assurance team will continue to conduct weekly R2T4 reviews to test the R2T4 calculation for accuracy, timeliness of funds returned, and verifying that all internal and external system inputs are completed correctly. Findings from the internal audits will inform ongoing training and remediation steps throughout the year. Name(s) of the contact person(s) responsible for corrective action: - Rob Conlon, AVP Financial Aid Compliance - Alan Coddington, AVP Student Financial Services - John Okel, Director of Operations, Financial Aid Processing Planned completion date for corrective action plan: January 2026

Categories

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1175614 2025-001
    Material Weakness Repeat
  • 1175615 2025-001
    Material Weakness Repeat
  • 1175616 2025-001
    Material Weakness Repeat
  • 1175617 2025-001
    Material Weakness Repeat
  • 1175618 2025-001
    Material Weakness Repeat
  • 1175620 2025-002
    Material Weakness Repeat
  • 1175621 2025-002
    Material Weakness Repeat
  • 1175622 2025-002
    Material Weakness Repeat
  • 1175623 2025-002
    Material Weakness Repeat
  • 1175624 2025-002
    Material Weakness Repeat
  • 1175625 2025-002
    Material Weakness Repeat
  • 1175626 2025-003
    Material Weakness Repeat
  • 1175627 2025-004
    Material Weakness Repeat
  • 1175628 2025-004
    Material Weakness Repeat
  • 1175629 2025-004
    Material Weakness Repeat
  • 1175630 2025-004
    Material Weakness Repeat
  • 1175631 2025-004
    Material Weakness Repeat
  • 1175632 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $283.30M
84.063 FEDERAL PELL GRANT PROGRAM $30.73M
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $2.36M
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $1.77M
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $1.76M
93.359 NURSE EDUCATION, PRACTICE QUALITY AND RETENTION GRANTS $933,273
84.411 EDUCATION INNOVATION AND RESEARCH (FORMERLY INVESTING IN INNOVATION (I3) FUND) $644,976
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $634,983
84.031 HIGHER EDUCATION INSTITUTIONAL AID $601,757
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $424,057
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $321,590
84.033 FEDERAL WORK-STUDY PROGRAM $256,650
84.428 AUGUSTUS F. HAWKINS CENTERS OF EXCELLENCE—TEACHER PREPARATION AND DEVELOPMENT $180,036
93.124 NURSE ANESTHETIST TRAINEESHIP $131,942
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $108,735
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $87,646
64.058 VETERAN AND SPOUSE TRANSITIONAL ASSISTANCE GRANT PROGRAM (VSTAGP) $80,808
12.902 INFORMATION SECURITY GRANTS $10,424
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $6,859
12.903 GENCYBER GRANTS PROGRAM $875
84.425 EDUCATION STABILIZATION FUND $-4,005