Finding Text
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all Title IV, Higher Education Act (HEA) program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not have adequate internal controls designed for return of Title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing we noted one instance where the College did not input the correct number of days when completing its return of funds calculation. We also noted one instance where the incorrect direct loan amount was used in the calculation. Cause: The College did not have formal procedures in place to review return of Title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: Yes, 2024-002 Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the finding. Financial aid staff have added to our Return to Title IV procedures that we complete the calculation in Colleague and the U.S. Department of Education Common Origination & Disbursement to make sure all amounts are correct. The Financial Aid Manager completes the calculation, and the Director then reviews and sends any questions/concerns back to the Financial Aid Manager. The Director will approve once any concerns are addressed.