Finding 1182290 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-24
Audit: 393699
Organization: Kellogg Community College (MI)

AI Summary

  • Core Issue: The College failed to perform timely return calculations for Title IV funds, impacting compliance with federal regulations.
  • Impacted Requirements: The College did not return unearned funds within the required 45 days, leading to material noncompliance.
  • Recommended Follow-Up: Implement stronger controls to ensure accurate inputs and timely reviews of Title IV calculations to prevent future errors.

Finding Text

Assistance Listing, Federal Agency, and Program Name Student Financial Assistance Cluster Federal Direct Student Loans Program (ALN 84.268), Federal Supplemental Educational Opportunity Grant Program (ALN 84.007), and Federal Pell Grant Program (ALN 84.063) Federal Award Identification Number and Year Various Pass through Entity None Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.220)(1)). 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 aid earned by the student as of the student's withdrawal date. The institution must return, in the order specified in paragraph (i) of this section, the lesser of (i) The total amount of unearned title IV assistance to be returned as calculated under paragraph (e)(4) of this section; or (ii) An amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of title IV grant or loan assistance that has not been earned by the student (34 CFR 668.220)(g)(1) Condition Out of 40 students tested for return to Title IV, we identified 2 students whose calculation were performed outside of the required timeframe. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context The College did not include institutional charges on returns during the fall 2024 semester and resulted in calculations that were not accurate. Management identified 40 students with inaccurate returns and corrected those returns, however 34 were completed outside of the allowable timeframe for completing the returns. Cause and Effect The College did not have appropriate controls in place to review the accuracy of the inputs used in performing the calculations. As a result, the College did not initially perform accurate calculations which caused revisions that were not timely. Recommendation The College should implement procedures and controls to review all inputs used in the Title IV calculations is accurate. Views of Responsible Officials and Corrective Action Plan Once the report identifying students who have completely withdrawn from their classes is ran, the calculations are done (currently by the Dean) The completed report is given to the FA Specialist to review and send the letters. The specialist then gives the report to the Assistant Director who then prints off a Return of Title IV summary report showing the calculations and charges for final review. Had this last step been done previously, it would have been identified that the Institutional Charges were missing and not requiring corrections.

Corrective Action Plan

Condition: Out of 40 students tested for return to Title IV, we identified 2 students whose calculation were performed outside of the required timeframe. Planned Corrective Action: Once the report identifying students who have completely withdrawn from their classes is ran, the calculations are done (currently by the Dean) The completed report is given to the FA Specialist to review and send the letters. The specialist then gives the report to the Assistant Director who then prints off a Return of Title IV summary report showing the calculations and charges for final review. Had this last step been done previously, it would have been identified that the Institutional Charges were missing and not requiring corrections. Contact person responsible for corrective action: Nikki Jewell Anticipated Completion Date: June 30, 2026

Categories

Student Financial Aid Material Weakness Reporting

Other Findings in this Audit

  • 1182284 2025-001
    Material Weakness Repeat
  • 1182285 2025-001
    Material Weakness Repeat
  • 1182286 2025-001
    Material Weakness Repeat
  • 1182287 2025-002
    Material Weakness Repeat
  • 1182288 2025-002
    Material Weakness Repeat
  • 1182289 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $8.76M
84.268 FEDERAL DIRECT STUDENT LOANS $3.60M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.25M
84.042 TRIO STUDENT SUPPORT SERVICES $288,280
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $216,133
84.033 FEDERAL WORK-STUDY PROGRAM $98,523
84.047 TRIO UPWARD BOUND $33,286
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $20,145
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $7,834
84.425 COVID-19 - EDUCATION STABILIZATION FUND $2,334