Finding Text
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In cases where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College had outstanding Title IV Federal Student Aid (FSA) checks issued to students that remained unclaimed for more than 240 days from the date of issuance. Questioned Costs: None Context: During testing of outstanding Title IV–funded checks, we identified three checks that exceeded 240 days from the date of issuance and had not been returned to the U.S. Department of Education. Cause: The College’s existing processes do not adequately monitor outstanding Title IV–funded checks to ensure timely identification and return of unclaimed funds. Effect: As a result, the College is not in compliance with federal requirements related to the return of unclaimed Title IV–funded checks issued to students or parents. Repeat Finding: Yes, 2024-003 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements and implement effective controls and procedures to monitor outstanding Title IV–funded checks throughout the year to ensure timely compliance. Views of responsible officials: There is no disagreement with the audit finding.