Finding 1181364 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-18
Audit: 392593
Organization: Millikin University (IL)
Auditor: SIKICH CPA LLC

AI Summary

  • Core Issue: The University failed to accurately calculate refunds for Title IV funds, affecting all official withdrawals reviewed.
  • Impacted Requirements: Non-compliance with 34 CFR 668.22 regarding timely and accurate return of federal financial aid funds.
  • Recommended Follow-Up: Implement ongoing training for staff on Title IV requirements and strengthen controls to ensure accurate refund calculations.

Finding Text

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” Condition: The University did not accurately complete refund calculations for official withdrawals. In review of the Fall 2024 official calculations the number of days in the break was not calculated correctly, resulting in the incorrect number of days in the calculation. The Title IV amounts for all withdrawn students were incorrectly calculated and returned for 5 out of the population of 5 (100%) Fall official withdrawal calculations. However, the No Passing Grade Sample for Fall unofficial withdrawals total number of days was calculated correctly. A sample of Spring official withdrawal calculations identified 2 calculation errors however the total days were calculated correctly. We noted 2 out of 4 (50%) Spring students tested in the Return of Title IV sample had incorrect calculations. Additionally, a sample of No Passing Grades students for unofficial withdrawals noted 2 out of 9 (22%) students tested did not have refund calculations completed timely. We consider this finding to be a material weakness in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was not used. Questioned Costs: $5,251 Cause and Effect: The cause was due to error and turnover in the Financial Aid Department. The effect is Return of Title IV funds calculations resulted in incorrect amounts returned by the College and untimely refund calculations. Recommendation: We recommend the University continually educate themselves on the requirements for the return of Title IV funds and ensure the proper controls are implemented to timely and accurately return unearned aid for official and unofficial withdrawals. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: The University did not accurately complete refund calculations for official withdrawals. In review of the Fall 2024 official calculations the number of days in the break was not calculated correctly, resulting in the incorrect number of days in the calculation. The Title IV amounts for all withdrawn students were incorrectly calculated and returned for 5 out of the population of 5 (100%) Fall official withdrawal calculations. However, the No Passing Grade Sample for Fall unofficial withdrawals total number of days was calculated correctly. A sample of Spring official withdrawal calculations identified 2 calculation errors however the total days were calculated correctly. We noted 2 out of 4 (50%) Spring students tested in the Return of Title IV sample had incorrect calculations. Additionally, a sample of No Passing Grades students for unofficial withdrawals noted 2 out of 9 (22%) students tested did not have refund calculations completed timely. We consider this finding to be a material weakness in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was not used. Management Response: We agree with this finding. Corrective Action Plan: This error was caused in a staff interpretation of a Saturday course being offered for one program. However, Saturday's are not on the academic calendar as a class day prior to the Thanksgiving break. Due to staff turnover, this was a change made in calculations in January 2025 that does not count that Saturday as a course day in regards to the length of Thanksgiving break. The change in days per semester calculation is now in line wiht the academic calendar posted by the institution. Responsible Person: Financial Aid Director/Registrar Implementation Date: January 2025

Categories

Student Financial Aid

Other Findings in this Audit

  • 1181361 2025-001
    Material Weakness Repeat
  • 1181362 2025-002
    Material Weakness Repeat
  • 1181363 2025-003
    Material Weakness Repeat
  • 1181365 2025-003
    Material Weakness Repeat
  • 1181366 2025-003
    Material Weakness Repeat
  • 1181367 2025-003
    Material Weakness Repeat
  • 1181368 2025-003
    Material Weakness Repeat
  • 1181369 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $9.95M
84.063 FEDERAL PELL GRANT PROGRAM $3.86M
84.038 FEDERAL PERKINS LOAN - FEDERAL CAPITAL CONTRIBUTIONS $517,003
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $352,088
84.033 FEDERAL WORK-STUDY PROGRAM $276,890
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $154,076
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $3,772