Finding Text
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Compliance, Other Matter Criteria or specific requirement: 34 CFR 668.22(a)(1) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a period of enrollment that the recipient began attendance in, the institution must determine the amount of Title IV assistance that the student earned in accordance with 34 CFR 668.22(e) which states that the calculation to determine this is equal to the percentage of the period of enrollment that the student completed as of the withdrawal date if this date occurs before completion of 60% of the period of enrollment. The amount unearned by the student is the complement of this percentage and is required to be returned as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as described in 34 CFR 668.22(j)(1). The withdrawal date is the date by which the student began the withdrawal process or provided official notification to the institution of intent to withdraw. If the student ceased attendance without providing notification to the institution the midpoint of the period of enrollment should be used. If the student’s ceasing attendance is due to illness, accident, or other circumstance beyond the students control the withdrawal date is date the institution becomes aware of these circumstances, as described in 668.22(c). Further (j)(2) states an institution not required to take attendance must determine the withdraw date for students who withdraw without providing notification to the institution no later than 30 days after the end of the earlier of the period of enrollment, academic year in which withdrawal occurred, or education program for which the student withdrew. Additionally, per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain effective internal controls designed to reasonably ensure compliance with federal laws, regulations, and program requirements related to these awards. Condition: The College did not accurately calculate Return of Title IV (R2T4) calculations. The College also did not maintain documentation of the internal controls to ensure the R2T4 process complied with federal regulations and guidelines. Questioned Costs: $5,458. Context: During our testing, it was noted out of our sample of 15, 2 students R2T4 calculation was not performed or not mechanically performed correctly. Additionally, the College does not have a formal review process in place to ensure compliance with federal laws, regulations, and program compliance requirements. Cause: The College does not have proper procedures in place to ensure R2T4 calculations are performed accurately and did not maintain documentation of the controls in place to ensure compliance with federal laws, regulation and program compliance requirements over R2T4. Effect: Failure to properly calculate R2T4 could result in the student returning an incorrect amount of aid. Further the lack of evidence of an internal control in place to ensure compliance with federal requirements could result in errors going undetected by the College. Repeat Finding: Yes, 2024-005. Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. We also recommend the College maintain evidence of the formal review process that ensures Return of Title IV calculations are being performed timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Views of responsible officials: There is no disagreement with the finding.