Finding 1176566 (2025-006)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-05
Audit: 390365
Organization: Johnson C. Smith University (NC)
Auditor: BDO USA PC

AI Summary

  • Core Issue: The University failed to refund Title IV credit balances to students within the required 14-day timeframe.
  • Impacted Requirements: Non-compliance with Title IV regulations regarding timely refunds of excess financial aid.
  • Recommended Follow-Up: Improve internal controls and procedures to ensure accurate and timely processing of Title IV refunds.

Finding Text

Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), and Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Title IV Credit Balance Refunds: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. As described in 34 CFR 668.164(c), institutions may credit (charge) a student’s ledger account with Title IV funds to pay for allowable charges associated with the payment period and prior year charges of not more than $200, in accordance with the timeframes described below. A prior year is any loan period or award year prior to the current loan period or award year, as applicable. An institution is permitted to hold credit balances if it obtains a voluntary authorization from the student. Regardless of any authorization obtained by the institution, the institution must pay any remaining loan balance by the end of the loan period and any other remaining Title IV funds by the end of the last payment period in the award year for which the funds were awarded. Condition: For certain students that had a credit balance on their account resulting from Title IV aid disbursements, the University did not refund the credit balance in the correct amount within the required timeframe. Cause: Insufficient administrative oversight and internal controls with respect to Title IV credit balance refunds. Effect or Potential Effect: The University was not in compliance with Title IV credit balance refunds requirements. Questioned Costs: Know questioned costs: $1,383; total questioned costs: indeterminable. Known questioned costs of $1,383 were identified as a result of the identified errors described in the Context below; sufficient information was not available to determine whether questioned costs may have resulted from similar issues in the untested population. Context: We noted the following exceptions during our testing: • For 3 of 22 sampled Title IV credit balances, the University did not fully refund the credit balance resulting from Title IV aid disbursements within the required timeframe. • For 1 of 22 sampled Title IV credit balances, the amount of Title IV credit balance was not resolved by the end of the payment period. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that credit balances on student accounts that are the result of Title IV aid disbursements are accurately refunded within the required timeframe. Views of Responsible Officials: The University acknowledges deficiencies in the Title IV Refund process. The deficiencies occurred as a result of process disruptions during the system transition to Ellucian Colleague. The University has strengthened its process and controls to ensure Title IV refunds are processed within 14 days.

Corrective Action Plan

Corrective Action Plan: To address the deficiencies identified in Finding 2025-006, The Offices of Student Accounts and Financial Aid offices (“the Offices”) will improve coordination and communication regarding the timing of fund transfers and refund disbursements. The Offices have established a schedule to begin the refund process 10 calendar days of the credit balance creation date to ensure compliance with the 14-day federal requirement. A written processing calendar has been established to track key deadlines and responsibilities. These actions establish preventive controls to ensure all Title IV credit balances are refunded within the federally required timeframe and to prevent recurrence. Ongoing monitoring of this process will ensure the University issues Title IV refunds within 14 days of the credit balance being applied to the student’s account. Anticipated Completion Date: December 2026

Categories

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1176550 2025-001
    Material Weakness Repeat
  • 1176551 2025-001
    Material Weakness Repeat
  • 1176552 2025-001
    Material Weakness Repeat
  • 1176553 2025-001
    Material Weakness Repeat
  • 1176554 2025-002
    Material Weakness Repeat
  • 1176555 2025-002
    Material Weakness Repeat
  • 1176556 2025-003
    Material Weakness Repeat
  • 1176557 2025-003
    Material Weakness Repeat
  • 1176558 2025-003
    Material Weakness Repeat
  • 1176559 2025-003
    Material Weakness Repeat
  • 1176560 2025-004
    Material Weakness Repeat
  • 1176561 2025-005
    Material Weakness Repeat
  • 1176562 2025-005
    Material Weakness Repeat
  • 1176563 2025-005
    Material Weakness Repeat
  • 1176564 2025-006
    Material Weakness Repeat
  • 1176565 2025-006
    Material Weakness Repeat
  • 1176567 2025-007
    Material Weakness Repeat
  • 1176568 2025-007
    Material Weakness Repeat
  • 1176569 2025-008
    Material Weakness Repeat
  • 1176570 2025-008
    Material Weakness Repeat
  • 1176571 2025-008
    Material Weakness Repeat
  • 1176572 2025-008
    Material Weakness Repeat
  • 1176573 2025-008
    Material Weakness Repeat
  • 1176574 2025-008
    Material Weakness Repeat
  • 1176575 2025-009
    Material Weakness Repeat
  • 1176576 2025-009
    Material Weakness Repeat
  • 1176577 2025-009
    Material Weakness Repeat
  • 1176578 2025-010
    Material Weakness Repeat
  • 1176579 2025-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $12.35M
84.063 FEDERAL PELL GRANT PROGRAM $6.16M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $2.38M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $499,663
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $457,333
84.120 MINORITY SCIENCE AND ENGINEERING IMPROVEMENT $401,852
84.033 FEDERAL WORK-STUDY PROGRAM $388,738
84.047 TRIO UPWARD BOUND $369,588
84.042 TRIO STUDENT SUPPORT SERVICES $366,285
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $269,267
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $232,533
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $201,323
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $185,839
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $48,474
89.003 NATIONAL HISTORICAL PUBLICATIONS AND RECORDS GRANTS $46,856
97.062 SCIENTIFIC LEADERSHIP AWARDS $26,250
97.061 CENTERS FOR HOMELAND SECURITY $15,207
11.417 SEA GRANT SUPPORT $5,250
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $4,800
93.310 TRANS-NIH RESEARCH SUPPORT $2,000
17.268 H-1B JOB TRAINING GRANTS $1,078
54.001 INTELLIGENCE COMMUNITY CENTERS FOR ACADEMIC EXCELLENCE $773