Finding 1176859 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-06

AI Summary

  • Core Issue: The College failed to return Title IV funds on time for five students, violating federal regulations.
  • Impacted Requirements: Noncompliance with 34 CFR 668.21(b) and 34 CFR 668.173(b) regarding timely refunds.
  • Recommended Follow-Up: Strengthen internal controls, improve monitoring, and train staff on federal return requirements to prevent future issues.

Finding Text

Finding Reference: 2025-001 Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Compliance Requirements: Return of Title IV Funds Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria: Under 34 CFR 668.21(b), institutions are required to return Title IV funds within 30 days of determining that a student never began attendance. Additionally, 34 CFR 668.173(b) requires institutions to return Title IV funds within the timeframes established under the federal cash management regulations, generally within 45 days of the date the institution determines a return is necessary. Institutions must also maintain internal controls sufficient to ensure accurate calculation and timely processing of required returns. Statement of Condition: The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30 day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Statement of Cause: The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30 day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Possible Asserted Effect: Failure to return Title IV funds within required timeframes places federal funds at risk and results in noncompliance with Title IV regulations. Continued deficiencies may expose the College to potential liabilities for improperly retained funds or increased oversight such as heightened cash monitoring. Questioned Costs: $10,349 Context: A sample of 50 students were selected for return to Title IV testing and 5 students were identified with untimely refunds. The sample was not intended to be, and was not, a statistically valid sample. The College has already returned these funds to the U.S. Department of Education. Repeat Finding: No Recommendation: The College should strengthen its internal controls and monitoring procedures to ensure compliance with federal return of funds requirements. This should include timely verification that calculated refund amounts match what is actually returned, improved review processes to confirm that students who never attended are identified promptly, and training for relevant staff to ensure consistent understanding and execution of federal aid return requirements. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges and accepts this finding. Processes that will mitigate this concern in the future had already been underway in the 2025-2026 aid year, and those practices, in addition to other steps we will take as part of the Corrective Action Plan, should eliminate future findings of this nature.

Corrective Action Plan

Corrective Action Plan Thursday, February 12, 2026 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the June 30, 2025 audit report dated February 13, 2026 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding): U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants, 804 Wayne Avenue, Chambersburg, Pennsylvania 17201 Finding Type: (per Finding) Federal Awards: Material Weakness in Internal Control over Compliance and Noncompliance Internal Control Type: (please choose the type per the finding)  Material Weakness(es) o Significant Deficiencies Audit Finding No.: 2025-001 Federal Program: (per Finding) Student Financial Assistance Cluster Compliance Requirement: (per Finding) Return of Title IV Funds Audit Finding Title/Statement of Condition: (copy from audit findings documentation): The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30-day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Auditor Recommendation: (copy from audit findings documentation) The College should strengthen its internal controls and monitoring procedures to ensure compliance with federal return-of-funds requirements. This should include timely verification that calculated refund amounts match what is actually returned, improved review processes to confirm that students who never attended are identified promptly, and training for relevant staff to ensure consistent understanding and execution of federal aid return requirements. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). The College has made several enhancements that should prevent future problems with the return of funds. 1) In fall 2025, the College instituted a new process for collecting data for attendance/participation of students. This process includes a data collection approximately one week into the part of term (the “Academic Participation Data Collection) – and before the disbursement of Title IV aid. It also includes follow up with faculty at several intervals throughout the semester to encourage them to withdraw students who have stopped attending. This improved process gives us clearer and more transparent data on attendance/participation so that aid recalculations and returns can be managed in a more timely manner 2) As of January 2025, the College has implemented a process to prevent the disbursement of Title IV (TIV) aid to students who are not enrolled in a future semester or are not considered actively attending. For example, if a student attended the Fall semester but is not enrolled for the Spring semester, Title IV funds cannot be disbursed if the aid was not originated before the student became ineligible. This process applies in both directions, as disbursement includes both paying funds to a student’s account and reversing funds when appropriate. Accordingly, the Previous Semester Fund Request process is designed to ensure that Title IV funds are either paid or reversed in compliance with federal requirements. 3) The Financial Aid team will continue processing returns at the time that an R2T4 occurs to prevent miscommunications and ensure timely completion. 4) The Financial Aid team and Finance teams will collaborate and engage Bank Mobile to improve the processing of stale checks and timed out funds. Anticipated Completion Date: May 1, 2026 Name(s) and Title(s) of contact person(s) responsible for correction action: Tim Barshinger, Associate Vice-president of Student Enrollment Services Juan Cordoba, Financial Aid Director

Categories

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring Cash Management Material Weakness Reporting

Other Findings in this Audit

  • 1176856 2025-001
    Material Weakness Repeat
  • 1176857 2025-001
    Material Weakness Repeat
  • 1176858 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $27.94M
84.063 FEDERAL PELL GRANT PROGRAM $23.53M
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $1.57M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $708,980
97.025 NATIONAL URBAN SEARCH AND RESCUE (US&R) RESPONSE SYSTEM $593,875
10.855 DISTANCE LEARNING AND TELEMEDICINE LOANS AND GRANTS $529,601
84.031 HIGHER EDUCATION INSTITUTIONAL AID $428,702
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $348,819
93.434 EVERY STUDENT SUCCEEDS ACT/PRESCHOOL DEVELOPMENT GRANTS $289,454
84.033 FEDERAL WORK-STUDY PROGRAM $196,370
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $187,684
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $72,102
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $27,578
94.006 AMERICORPS STATE AND NATIONAL 94.006 $13,344
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $7,322