Finding Text
Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in "Schedule of Findings and Questioned Costs"). Criteria – When a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. The regulations (34 CFR 668.22(j)(1)) provide that an institution must return the amount of title IV funds for which it is responsible under this paragraph (34 CFR 668.22(a)(6)(ii)(B)(1)) as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. In addition, the University is required to maintain internal controls to ensure that the calculation of all returns are complete and accurate which includes documentation of reviews and approvals when completed by an individual other than who prepared them. Condition/Context – We selected a sample of 20 students out of a population of 109 that were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. We believe this to be a representative sample of the population; however, it was not a statistical sample. Effect – We found exception with one student whose title IV funds were returned 48 days after it was determined that the student had withdrawn. We also could not observe retained evidence that any of the calculations were reviewed and approved by an individual other than who prepared them. Cause – The FY2024 Corrective Action Plan (CAP) was approved in November 2024, near the end of the Fall 2024 term, with a projected completion date of December 2024. The associated finding pertains to Fall 2024 unofficial withdrawals and was identified through a report developed by the Registrar’s Office in response to this CAP. Development of the report could not begin until after November 2024 and required at least two months to complete to ensure accuracy of data output. Consequently, processing for this student was delayed, as completion of the report took longer than initially anticipated. Additionally, management’s current procedures do not require retention of documentation to support reviews and approvals of R2T4 calculations. Questioned Costs – None. Repeat Finding – This is a repeat finding, see 2024-001. Recommendation – We recommend the University’s management update the internal control procedures in place to process R2T4 returns in a timely manner and ensure that documentation is retained for evidence that the calculations were reviewed and approved by someone other than who prepared them to ensure the completeness and accuracy of the calculations. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See the corrective action plan for further detail.