Finding 1177953 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-11
Audit: 391360
Auditor: WIPFLI LLP

AI Summary

  • Core Issue: Five out of nine student files had incorrect Return of Title IV (R2T4) calculations, affecting withdrawal dates.
  • Impacted Requirements: Students B and D are required to return funds due to ineligibility based on the College’s policies.
  • Recommended Follow-Up: Review and correct R2T4 calculations for affected students and ensure compliance with Title IV funding policies.

Finding Text

The examination disclosed 5 students, out of 9 withdrawn student files tested, in which their Return of Title IV calculation was performed incorrectly. Student A – According to the R2T4 calculation the date of determination is 3/25/25 which is before the date of withdrawal of 4/10/25. No funding was effected. Student B – According to the R2T4 calculation the date of determination is 3/3/25 which is before the date of withdrawal of 3/31/25. The student was only eligible for 50% of their Title IV aid based on the College’s policies and procedures. The College should return $808 to Pell. Student C – According to the R2T4 calculation the date of determination is 2/20/25 which is before the date of withdrawal of 3/31/25. No funding was effected. Student D – According to the R2T4 calculation the date of determination is 3/11/25 which is before the date of withdrawal of 4/17/25. The student is only eligible for 50% of Title IV funds according to the College’s policies and procedures, $1,386.5 of Pell should be returned. Student E – According to the R2T4 calculation the date of determination is 2/20/25 which is before the date of withdrawal of 2/21/25. No funding was effected.

Corrective Action Plan

Corrective Action Plan for Current Year Findings 2025-001 Special Tests & Provisions – Return of Title IV Funds This Corrective Action Plan has been established by the Financial Aid and Registrar’s Offices to resolve findings related to Return of Title IV (R2T4) calculation errors. The goal of this plan is to ensure 100% data integrity through enhanced system logic, multi-tier manual verification, and cross-departmental reconciliation. Identify and Analyze Errors: The institution conducted a root-case analysis of the identified findings and determined the following: R2T4 Transposition Errors: For five (5) student records, the "Date of School’s Determination" (DOD) and the "Date of Withdrawal/Last Date of Engagement" (LDE) were inadvertently switched during manual entry into the COD system. Corrective Standard: The Withdrawal Date must be verified as the actual Last Date of Engagement (LDE), while the Date of Determination must remain the Banner-stamped withdrawal date. Develop and Implement Data Verification Processes: To prevent recurrence, the following "intrusive checks and balances" system has been implemented: Multi-Tier R2T4 Review (Financial Aid) - A four-point verification process is now mandatory for all Pro-rata calculations: a. Preparation: Financial Aid Specialist calculates the return based on Banner data. b. Validation: Financial Aid Coordinator validates the LDE and DOD against the academic record. c. Confirmation: Financial Aid Manager reviews and confirms previous calculations based on LDE and Banner data. d. Final Oversight: The Director of Financial Aid performs the final verification check before and after the data is committed to the Common Origination and Disbursement (COD) system. e. Standardization: All calculations must include employee initials and date within the Pro-rata Calculation Form, based on the 4-point verification process above, to ensure internal record reconciliation. Person(s) Responsible: Christine Genenbacher-Leinbach, Director of Financial Aid Brittany McKeown, Head of Enrollment, Registrar, Financial Aid Services Timing for Implementation: Currently implemented, as well as a retroactive check of prior R2T4 submissions, starting September 1, 2025. New verification tiers are active as of the current term to ensure immediate compliance without further incidents.

Categories

Student Financial Aid

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $4.09M
84.268 FEDERAL DIRECT STUDENT LOANS $1.16M
84.047 TRIO_UPWARD BOUND $364,579
84.044 TRIO_TALENT SEARCH $355,796
84.042 TRIO_STUDENT SUPPORT SERVICES $340,181
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $167,780
94.002 RETIRED AND SENIOR VOLUNTEER PROGRAM $119,822
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $84,652
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $76,764
84.033 FEDERAL WORK-STUDY PROGRAM $67,252
81.117 ENERGY EFFICIENCY AND RENEWABLE ENERGY INFORMATION DISSEMINATION, OUTREACH, TRAINING AND TECHNICAL ANALYSIS/ASSISTANCE $16,615
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $4,831