Finding 1186895 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-26
Audit: 394669
Auditor: RSM US LLP

AI Summary

  • Core Issue: The Conservatory miscalculated the number of days for Title IV aid calculations, leading to incorrect aid percentages for two students.
  • Impacted Requirements: This finding violates federal regulations requiring accurate calculations of Title IV aid earned based on the completed calendar days.
  • Recommended Follow-Up: Strengthen controls over Return of Title IV Funds (R2T4) calculations to ensure compliance with federal requirements.

Finding Text

Finding 2025 001 – Return of Title IV Funds Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.063, 84.268 Federal Agency: U.S. Department of Education Federal Awards Year 2024-2025 Criteria: Federal regulations require institutions to determine the amount of Title IV aid earned by a student who withdraws by calculating the percentage of the payment period or period of enrollment completed using calendar days completed divided by total calendar days in the period, in accordance with 34 CFR 668.22(e). An accurate calculation of days in the payment period is necessary to determine the correct amount of Title IV aid earned and unearned. Condition: Of the 2 students selected for testing of Title IV disbursements, the Conservatory improperly calculated the number of days used in the Return of Title IV Funds calculation for the Fall 2024 semester, resulting in an incorrect percentage of Title IV aid earned for both students. Consequently, the amount of Title IV aid refunded was not calculated in accordance with federal requirements. Cause: The Conservatory did not have sufficient controls in place to ensure the accurate calculation of calendar days in the payment period used for R2T4 calculations. Effect: As a result, the Conservatory did not properly calculate the amount of Title IV aid earned and unearned, resulting in additional funds returned to the Department. Questioned Costs: $1,108 Repeat Finding: No. Recommendation: The Conservatory should strengthen controls over R2T4 calculations to ensure that the number of calendar days used in determining earned Title IV aid is calculated accurately and in accordance with federal requirements. View of Responsible Officials: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Finding No. 2025-001 – Return of Title IV Funds Finding: During the audit, for the 2 students selected for testing of Title IV disbursements, the institution improperly calculated the number of days used in the Return of Title IV Funds (R2T4) calculation for the Fall 2024 semester, resulting in an incorrect percentage of Title IV aid earned. Consequently, the amount of Title IV aid refunded was not calculated in accordance with federal requirements. Corrective Action Taken or Planned: Senior management at NEC takes Title IV requirements seriously. Moving forward, the institution review its academic calendar and will strengthen controls over R2T4 calculations to ensure that the number of calendar days used in determining earned Title IV aid is calculated accurately and in accordance with federal requirements. Responsible Person: Rebecca Barry-Wolff, Director of Student Financial Planning Update: The corrective actions noted are all in place for fiscal year 2026.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1186893 2025-001
    Material Weakness Repeat
  • 1186894 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $6.11M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $533,836
84.063 FEDERAL PELL GRANT PROGRAM $287,140
84.033 FEDERAL WORK-STUDY PROGRAM $271,237
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $121,247