Finding 1176205 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-03

AI Summary

  • Core Issue: 13 out of 60 students had Title IV funds not returned within the required 45-day limit after withdrawal.
  • Impacted Requirements: Non-compliance with 34 CFR 668.22(a)(1) and (b), which mandates timely return of Title IV funds.
  • Recommended Follow-Up: Enhance R2T4 procedures with ongoing staff training and implement additional reviews for accuracy and compliance.

Finding Text

Criteria: 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. In accordance with 34 CFR 668.22(b) and (d)(4),the institution must return those funds for which it is responsible under paragraph (a) of this section to the respective title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. An institution does not satisfy this requirement if— (i) The institution's records show that the check was issued more than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 45 days after the date that the institution becomes aware that the student will not or has not begun attendance. Condition: It was noted during our testing of R2T4 calculations that 13 of 60 students selected for R2T4 testing had an instance of non-compliance due to Title IV funds not being returned within the 45 day time limit. Questioned Costs: None. Context: During our audit procedures, we noted 13 of the 60 students selected for R2T4 testing had Title IV funds not returned within the 45-day time limit. Cause: During fiscal year 2025, the District implemented additional procedures to strengthen the R2T4 process in response to the fiscal year 2024 audit finding. Because the 2024 audit report was issued after certain R2T4 calculations had already been completed, the newly implemented procedures resulted in corrections to some previously finalized calculations. 4 of the 13 instances of non‑compliance were attributable to these post‑implementation corrections. The remaining 9 instances of non‑compliance resulted from human error. Effect: The District did not return Title IV funds within the required time period. Repeat Finding: Yes, 2024-001. Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Views of Responsible Officials: Management concurs with the finding.

Corrective Action Plan

Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Action taken in response to finding: The District acknowledges the importance of compliance with Return to Title IV (R2T4) requirements. The repeat finding cited in the subsequent audit relates to files processed prior to implementation of the corrective action plan. Since implementation, the District has not identified any new R2T4 errors or compliance issues. Action taken in response to finding: 1. Prior-Year File Remediation • Recalculated R2T4 amounts for affected students. • Returned required funds to the U.S. Department of Education. 2. Oversight and Review Controls • Engaged a NASFAA-certified consultant to review all R2T4 calculations during the 2024–2025 aid year. • Implemented secondary internal review of all R2T4 calculations. 3. Training and Staffing Enhancements • Completed department-wide and R2T4-specific training. • R2T4 staff completed NASFAA R2T4 course series. • An additional Accounting Officer position was added to support R2T4 processing and reconciliation with appropriate system access. 4. Process Improvements • Transitioned to the Department of Education’s R2T4 worksheet in COD. • Established formal coordination with Academic Affairs and the Registrar. • Updated R2T4 training and job aids. 5. Ongoing Monitoring • Management performs periodic internal reviews of R2T4 files. • The District continues to evaluate system and reporting enhancements. Conclusion Although the audit included R2T4 files processed prior to corrective action implementation, the District’s actions have been effective. No new R2T4 issues have been identified since implementation, and controls are in place to ensure ongoing compliance. Name of the contact person responsible for corrective action: David Brown, Acting Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: June 30, 2026

Categories

Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1176202 2025-003
    Material Weakness Repeat
  • 1176203 2025-003
    Material Weakness Repeat
  • 1176204 2025-003
    Material Weakness Repeat
  • 1176206 2025-004
    Material Weakness Repeat
  • 1176207 2025-004
    Material Weakness Repeat
  • 1176208 2025-004
    Material Weakness Repeat
  • 1176209 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Pell Grant $40.31M
84.007 Supplemental Educational Opportunities Grant (SEOG) $1.04M
84.048 Perkins Title I-C (Basic Grants to States) $924,947
84.268 Federal Direct Student Loans $724,252
84.033 Federal Work Study (FWS) $705,431
84.031 WINGS-Warrior Initiative $506,035
59.037 Small Business Development Center (SBDC) $274,885
84.116 ECC Warriors Resource Program $249,756
64.117 Veterans Education $238,532
93.558 Temporary Assistance for Needy Families (TANF) $210,487
84.002 Workforce Innovation and Opportunity Act, Title II (WIOA) $176,876
84.116 Warriors STEM Industry Program $164,942
11.611 Manufacturing Extension Partnership $163,211
47.076 Replication of Cohort-Based Computer Science Bachelor's Degree Model $144,518
93.658 Foster and Kinship Care Education Program $110,928
12.617 Effort Phase II (CASCADE II) Project $99,289
81.253 CA Smart Manufacturing Leadership Program (CA SMLP) $95,511
84.423 Center for Collaborative Education $47,935
12.600 California Advanced Defense Ecosystems & California Advanced Supply Chain Analysis and Diversification $45,252
10.580 CalFresh SNAP Outreach Program (CFO) $42,766
94.006 AmeriCorps National Service Awards $3,228
47.070 Frontier Opportunities in Computing for Underrepresented Students $3,148
93.778 Medi-Cal Administrative Activities $1,036