Finding 1218138 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-22

AI Summary

  • Core Issue: The College lacks a control to monitor outstanding Title IV federal checks, risking non-compliance with federal requirements.
  • Impacted Requirements: 2 CFR part 200.303 and 34 CFR 688.164 mandate timely return of unclaimed funds within 240 days.
  • Recommended Follow-Up: Implement a monitoring control for outstanding Title IV checks to ensure compliance and timely returns.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriate federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In cases where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Unclaimed Title IV FSA funds must not escheat to the state, revert to the College, or be transferred to any other third party. Condition: The College does not have a control in place to specifically monitor outstanding Title IV federal funded checks issued to students. This absence of oversight prevents the College from ensuring that these funds are returned within 240 days of check issuance. Questioned Costs: N/A. Context: During our testing, it was noted the College did not have a control in place to ensure the return of outstanding Title IV federally funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. Cause: The College did not have a control in place to ensure outstanding Title IV checks over 240 days are sent back to the Department of Education. Effect: The College is not in compliance with Department of Education requirements to establish internal controls over outstanding checks and refunds of disbursements to students. Repeat Finding: Yes, 2024-003. Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks. Views of responsible officials: There is no disagreement with the finding.

Corrective Action Plan

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On a monthly basis, as part of the bank reconciliation process, the Business Office generates a report of outstanding student refund checks and reviews it for uncashed items. Uncashed Title IV checks are recorded on a tracking log noting check number, issue date, and amount. When a check remains uncashed for 120 days, the Business Office contacts the student to confirm receipt or determine whether a reissue is needed, and the outreach is documented on the log. The monthly review and log are signed and dated by the preparer; co-signed by the Vice President of Administrative Services, and documentation is retained including months in which no exceptions are noted. At the conclusion of the monthly review process, an email with subject line: Uncashed Refund Checks is forwarded to the Financial Aid Office which includes a spreadsheet listing the students with uncashed refund checks or a note that there were no records for that particular month. Any Title IV check that remains uncashed is canceled by the Business Office. Within 5 - 7 business days of receiving the notification from the Business Office, the Financial Aid Office will notify the third-party servicer, Global Financial Aid Services (herein after referred to as Global) through their established reporting mechanism (GARP) to ensure the funds are returned to the Department of Education no later than 240 days after the date of issuance, as required by 34 CFR 668.164(h). Name(s) of the contact person(s) responsible for corrective action: Sam Draper and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

Categories

Internal Control / Segregation of Duties Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1218125 2025-001
    Material Weakness Repeat
  • 1218126 2025-002
    Material Weakness Repeat
  • 1218127 2025-003
    Material Weakness Repeat
  • 1218128 2025-004
    Material Weakness Repeat
  • 1218129 2025-005
    Material Weakness Repeat
  • 1218130 2025-006
    Material Weakness Repeat
  • 1218131 2025-001
    Material Weakness Repeat
  • 1218132 2025-002
    Material Weakness Repeat
  • 1218133 2025-003
    Material Weakness Repeat
  • 1218134 2025-004
    Material Weakness Repeat
  • 1218135 2025-005
    Material Weakness Repeat
  • 1218136 2025-006
    Material Weakness Repeat
  • 1218137 2025-001
    Material Weakness Repeat
  • 1218139 2025-003
    Material Weakness Repeat
  • 1218140 2025-004
    Material Weakness Repeat
  • 1218141 2025-005
    Material Weakness Repeat
  • 1218142 2025-006
    Material Weakness Repeat
  • 1218143 2025-001
    Material Weakness Repeat
  • 1218144 2025-003
    Material Weakness Repeat
  • 1218145 2025-004
    Material Weakness Repeat
  • 1218146 2025-005
    Material Weakness Repeat
  • 1218147 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.52M
84.268 Federal Direct Student Loans $757,131
93.575 Child Care and Development Block Grant $708,279
84.031 Building Equitable Access and Success Project (EASE) $517,378
11.307 COVID-19 Economic Adjustment Assistance $475,788
11.617 Congressionally Identified Projects Program (CIPP) $310,585
17.258 WIOA Adult Program $171,909
84.002 Adult Education - Basic Grants to States $155,735
17.259 WIOA Youth Activities $142,320
47.076 STEM Education (formerly Education and Human Resources) $138,719
21.027 COVID 19 State and Local Fiscal Recovery Funds - Prosperity 10k $109,170
21.027 COVID-19-ESOL Fiscal Recovery Funds $99,596
17.278 WIOA Dislocated Worker Formula Grants $91,599
21.027 COVID-19 State and Local Fiscal Recovery Funds $62,351
84.007 Federal Supplemental Educational Opportunity Grants $58,050
21.027 COVID 19 State and Local Fiscal Recovery Funds - Ben Nav $32,805
59.037 Development Center Network Office: Small Business Development Center $31,790
84.033 Federal Work-Study Program $24,808
17.277 WIOA National Dislocated Worker Grants / WIA National Emergency Grants $24,232
15.228 BLM Fuels Management and Community Fire Assistance Program Activities $19,914
21.027 COVID 19 State and Local Fiscal Recovery Funds - EOWP Reentry $7,175