Finding 1176904 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-09

AI Summary

  • Core Issue: Franklin Cummings Tech awarded Pell funds to a student after their withdrawal date, resulting in unearned funds.
  • Impacted Requirements: The institution failed to follow federal regulations for calculating and returning unearned Title IV funds as outlined in 34 CFR 668.22(e).
  • Recommended Follow-Up: Strengthen internal controls over the Return of Title IV process to ensure accurate calculations and timely returns of unearned funds.

Finding Text

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Criteria According to 34 CFR 668.22(e): (1) General. The amount of title IV grant or loan assistance that is earned by the student is calculated by— (i) Determining the percentage of title IV grant or loan assistance that has been earned by the student, as described in paragraph (e)(2) of this section; and (ii) Applying this percentage to the total amount of title IV grant or loan assistance that was disbursed (and that could have been disbursed, as defined in paragraph (l)(1) of this section) to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date. (4) Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Department is responsible for completing the Return of Title IV calculation to determine how much Title IV funds the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, Franklin Cummings Tech is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). During our testing, we noted 1 student, out of a sample of 32, who was awarded Pell after the student’s withdrawal date, which the student had not earned. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals and return unearned Title IV funds to the Department of Education. Effect Franklin Cummings Tech granted Pell funds in excess of the amount earned by the student. Questioned Costs $3,697 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 32 students selected for testing, 1 student, or 3.1% of our sample, had unearned Title IV funds that were not returned to the Department of Education. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its internal controls over the Return of Title IV (R2T4) process, including monitoring student withdrawals and reviewing calculations, to ensure earned funds are calculated correctly and unearned portions are returned to the Department of Education. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Corrective Action Plan

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Corrective Action Plan Contact Person: Sabina Yesman, Director of Financial Aid A PELL Grant was awarded and disbursed for one ineligible student during the 2024-2025 Academic Year at Benjamin Franklin Cummings Institute of Technology (FC Tech). The error resulted from incomplete synchronization between enrollment and financial aid systems during the system transition period. Specifically, enrollment status and census-date verification were not fully integrated into the automated disbursement workflow, allowing aid to disburse before final eligibility confirmation. FC Tech has taken corrective measures and implemented monitoring and system controls to prevent future errors from occurring. Corrective Action Taken  FC Tech reviewed the student’s record and confirmed the ineligibility.  The PELL Grant award was adjusted to $0, and the disbursement was reversed.  The student account was corrected, and all required accounting and G5 drawdown adjustments were completed. The amount of $3,697 was returned on 12/18/2025  The case was documented internally for training purposes. Preventive Measures Implemented (February 2026) To prevent recurrence, FC Tech has implemented the following controls:  Enrollment Verification Prior to Disbursement All PELL-eligible students must be actively enrolled and confirmed in the Student Information System (Jenzabar) prior to disbursement.  Census-Date Verification Through Multiple Systems Enrollment status at census date is now validated through an integrated, multi-system verification process involving the Jenzabar, our Financial Aid System (PowerFAIDS), and Registrarconfirmed Enrollment Reports.  Delayed Disbursement Timeline Federal Aid disbursements are scheduled to occur no earlier than one week after census date to allow sufficient time for enrollment stabilization, drops, corrections and reconciliation  System Edit/Control Automated system edits have been implemented to prevent a PELL disbursement if census-date enrollment status is missing, unconfirmed, or inconsistent across systems.

Categories

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $2.28M
84.268 FEDERAL DIRECT STUDENT LOANS $1.78M
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $1.13M
17.289 COMMUNITY PROJECT FUNDING/CONGRESSIONALLY DIRECTED SPENDING $523,799
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $284,639
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $73,841
16.812 SECOND CHANCE ACT REENTRY INITIATIVE $69,123
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $50,519
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $48,581
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $35,054
84.033 FEDERAL WORK-STUDY PROGRAM $15,803