Finding 1206598 (2025-001)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-04-14
Audit: 398656
Organization: Broome Community College (NY)
Auditor: BONADIO & CO LLP

AI Summary

  • Core Issue: Errors in returning Title IV funds due to inadequate review controls and lack of segregation of duties.
  • Impacted Requirements: Compliance with federal regulations for the accurate calculation and return of unearned Title IV funds.
  • Recommended Follow-Up: Strengthen internal controls by implementing formal procedures for reviewing R2T4 calculations and ensuring correct fund returns.

Finding Text

Finding 2025-001 – Student Financial Assistance Cluster Federal Agency – U.S. Department of Education Grant Period – Year ended August 31, 2025 Compliance Requirement – Return of Title IV Funds Criteria – Federal regulations require institutions to calculate and return unearned Title IV funds. Condition – During our testing for Return of Title IV (R2T4) calculations, we identified 2 instances out of 25 students selected for testing where the R2T4 was properly calculated. However, the Title IV funds were not correctly and accurately returned. Cause – The College had a lack of review controls and segregation of duties in their Return of Title IV Funds process. Based on discussion with the client, these errors were manual errors that were not identified due to a lack of review control and segregation of duties. As a result, the controls over Return of Title IV funds were not operating effectively. Effect – The amount and type of Title IV funds were not being returned correctly. Recommendation – We recommend that management strength internal controls over correctly and accurately returning Title IV funds by implementing formalized procedures to ensure proper review of the R2T4 calculation and review that the correct type and amount of funds are returned. Management Response – The College acknowledges the instances identified during testing where the errors in the calculation of Return to Title IV (R2T4) funds, resulted in incorrect amounts of federal aid being returned for certain withdrawn students. These instances were the result of manual processing errors that were not identified due to a lack of review control and segregation of duties. R2T4 calculations and return amounts were completed and finalized by a single staff member without a required secondary review, increasing the risk of calculation errors.

Corrective Action Plan

The institution reviewed the identified R2T4 calculations and, where necessary, corrected the amounts returned to ensure compliance with federal regulations. The College implemented several procedural and staffing changes to strengthen internal controls and improve segregation of duties related to the Return of Title IV Funds process. These improvements include: • Establishing a formal secondary review of all R2T4 calculations and fund return transactions prior to processing. A second qualified Finance staff member will review and verify: • The withdrawal date • The calculation methodology • The percentage of the payment period completed • The final amount of Title IV funds returned • Separating responsibilities for calculation, review, and posting of Title IV fund returns to ensure appropriate segregation of duties. • Implementing documented procedures and checklists to verify that the correct type and amount of Title IV funds are returned in accordance with federal requirements. • Providing additional staff training related to R2T4 processing and compliance requirements. Management believes that these corrective actions significantly strengthen internal controls and reduce the likelihood of similar errors occurring in the future. The College will continue to monitor compliance with these procedures and perform periodic supervisory reviews to ensure that controls remain effective.

Categories

Internal Control / Segregation of Duties Student Financial Aid

Other Findings in this Audit

  • 1206595 2025-001
    Material Weakness Repeat
  • 1206596 2025-001
    Material Weakness Repeat
  • 1206597 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $11.52M
84.063 FEDERAL PELL GRANT PROGRAM $10.27M
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $478,482
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $261,951
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $219,975
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $180,400
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $122,679
17.261 WORKFORCE DATA QUALITY INITIATIVE (WDQI) $103,449
84.033 FEDERAL WORK-STUDY PROGRAM $75,396
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $62,808
84.015 NATIONAL RESOURCE CENTERS PROGRAM FOR FOREIGN LANGUAGE AND AREA STUDIES OR FOREIGN LANGUAGE AND INTERNATIONAL STUDIES PROGRAM AND FOREIGN LANGUAGE AND AREA STUDIES FELLOWSHIP PROGRAM $18,005
47.050 GEOSCIENCES $12,922
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $11,543
17.270 REENTRY EMPLOYMENT OPPORTUNITIES $10,340
93.667 SOCIAL SERVICES BLOCK GRANT $6,301
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $5,859
93.778 MEDICAL ASSISTANCE PROGRAM $5,814
93.658 FOSTER CARE TITLE IV-E $2,586
93.563 CHILD SUPPORT SERVICES $2,055
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $990