Finding 1180982 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-18
Audit: 392509
Organization: Bergen Community College (NJ)

AI Summary

  • Core Issue: The College failed to accurately calculate and return Title IV funds for withdrawn students, impacting compliance with federal requirements.
  • Impacted Requirements: Timely return of funds and proper notification for post-withdrawal disbursements were not met for multiple students.
  • Recommended Follow-up: Implement stricter adherence to policies and procedures for Title IV fund calculations and returns to prevent future noncompliance.

Finding Text

2025-002 Special Tests and Provisions – Return of Title IV Funds – Significant Deficiency Federal Assistance Listing Numbers: 84.063, 84.007, 84.268, and 84.033 Name of Program or Cluster: Student Financial Assistance Cluster Agency: U.S. Department of Education Criteria: The College is required to accurately calculate return of Title IV funds for withdrawn students who began attendance, allocate the return of Title IV funds as required, notify borrowers of returned loans and/or follow the requirements for post-withdrawal disbursements as applicable. Additionally, where applicable, the College is required to return funds within forty-five days of becoming aware that the student had withdrawn, deposits or transfers were made into the federal funds account, electronic transfers were initiated, or checks were issued. Condition: The College did not accurately calculate a return of Title IV funds and/or follow the requirements for post-withdrawal disbursements for nine out of sixty students sampled from a total population of withdrawn students who began attendance. Additionally, for fifteen out of the sixty students sampled, the College did not return Title IV funds timely. Cause: Management oversight. Effect: Noncompliance with OMB federal grant compliance requirements. Questioned Costs: None. Repeat Finding: Yes. Recommendation: The College should properly follow its policies and procedures over return of Title IV funds to ensure that all R2T4 calculations are completed accurately and timely and all requirements for post-withdrawal disbursements are followed where applicable. Views of Responsible Officials: See Corrective Action Plan attached.

Corrective Action Plan

Views of Responsible Officials: The College acknowledges the audit finding that Return of Title IV (R2T4) calculations were not accurately completed for nine of the sixty students sampled, and that Title IV funds were not returned timely for fifteen of the sixty students sampled. During the audit period, R2T4 tracking and oversight processes were in transition, which resulted in insufficient monitoring of calculation accuracy and timeliness. In addition, for several end-of-term cases involving unofficial withdrawals, the institution could not initiate R2T4 calculation until final grades were posted and an unofficial withdrawal determination was made based on non-passing (F) grades, in accordance with federal regulations governing unofficial withdrawals. The Fall 2024 semester ended on December 21st. The college was closed for the winter break and reopened January 2, 2025. Therefore, the Date of Determination (DOD) was not two days after the end of the semester but in January with the earliest available processing date being January 2, 2025. Corrective Action: The College has implemented enhanced internal controls to ensure compliance with Return of Title IV (R2T4) requirements. Responsibility for monitoring R2T4 calculations and timeliness has been assigned to the Director of Financial Aid and Compliance. A R2T4 tracking log has been established and is reviewed on a weekly basis to ensure that all official withdrawals are identified and processed within the required regulatory timeframe. For unofficial withdrawals, R2T4 calculations are initiated after the end of term once final grades are posted and an unofficial withdrawal date of determination (DOD) is made based on non-passing (F) grades, consistent with federal regulations. End-of-term R2T4 reviews for the fall semester are conducted upon return from winter break after the New Year to ensure complete and accurate academic records are available. Internal staff have received additional training on R2T4 regulatory requirements, timelines, and documentation standards. To ensure operational continuity, a senior specialist has been trained to manage R2T4 processing in the Director's absence. These corrective actions will strengthen internal controls and ensure accurate and timely processing of R2T4 calculations.

Categories

Special Tests & Provisions Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1180975 2025-002
    Material Weakness Repeat
  • 1180976 2025-002
    Material Weakness Repeat
  • 1180977 2025-002
    Material Weakness Repeat
  • 1180978 2025-002
    Material Weakness Repeat
  • 1180979 2025-003
    Material Weakness Repeat
  • 1180980 2025-003
    Material Weakness Repeat
  • 1180981 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $26.73M
84.268 FEDERAL DIRECT STUDENT LOANS $6.17M
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $856,032
10.237 FROM LEARNING TO LEADING: CULTIVATING THE NEXT GENERATION OF DIVERSE FOOD AND AGRICULTURE PROFESSIONALS $671,644
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $582,840
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $467,077
84.033 FEDERAL WORK-STUDY PROGRAM $387,724
84.031 HIGHER EDUCATION INSTITUTIONAL AID $267,350
10.223 HISPANIC SERVING INSTITUTIONS EDUCATION GRANTS $177,741
84.407 TRANSITION PROGRAMS FOR STUDENTS WITH INTELLECTUAL DISABILITIES INTO HIGHER EDUCATION $91,088
66.951 ENVIRONMENTAL EDUCATION GRANTS PROGRAM $65,723
84.335 CHILD CARE ACCESS MEANS PARENTS IN SCHOOL $50,796
59.059 CONGRESSIONAL GRANTS $50,163
17.268 H-1B JOB TRAINING GRANTS $19,527
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $6,697