Finding 1221346 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-30
Audit: 405683
Organization: College of the Muscogee Nation (OK)
Auditor: HOGANTAYLOR LLP

AI Summary

  • Core Issue: The calculation of Title IV Assistance earned was not completed on time for two students who withdrew, violating Title 34 requirements.
  • Impacted Requirements: Institutions must accurately calculate and process returns of Title IV funds within the specified timeframe to support student financial wellbeing.
  • Recommended Follow-up: The Financial Aid Coordinator should implement a procedure to ensure timely completion of the Title IV worksheet and processing of returns.

Finding Text

Item 2025-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of the withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Out of a sample of eight students who withdrew during the audit period, the Title IV worksheet was not completed within the maximum time allowed for two students that required a return of funds. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures were not in place to verify that the Title IV worksheet was completed timely. Finding is a repeat of finding 2024-002 in the immediately prior audit. Not timely preparing a calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed timely to ensure the processing of returns is completed within the required time frame. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Corrective Action Plan

Corrective Action Plan (CAP): The College has identified that the dates of Return of Title IV Calculations and amounts (in one case) were out of compliance. The return calculations for both students identified through this audit have been completed and corrected to reflect the correct return amounts, if appropriate. Student 1: Student initiated an official withdrawal on October 5, 2024, and the withdrawal was processed on that date. A notification of student status was not received in the financial aid office in order to trigger an R2T4 calculation. This student's calculation was performed at the end of the fall 2024 term with the end of term processing, resulting in 89 days passing from notification to completion of R2T4. This instance resulted in an automatic trigger being built into the student information system, which sends an email to the financial aid office for each student when their status changes from active to withdrawal. Student 2: Student initiated an official withdrawal on February 13, 2025, and the withdrawal was processed on that date. The R2T4 calculation was not performed on this student until the end of spring 2025 term processing, resulting in 96 days passing from notification to completion of R2T4. Due to delayed calculations on these students, CMN will continue to work with financial aid staff and the registrar's office to streamline communication on withdrawals and students who complete the term with all F/NP grades, as indicated in CMN policy. CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. Additionally, Enrollment Management notifies all faculty by email at the beginning of the term and again prior to final grades being submitted that electronic notification must be sent by the faculty to financial aid in order to alert the financial aid office of the date of last academic engagement for students who earn an For NP grade. For the current audit period, the Director of Enrollment Management and the Financial Aid Coordinator work together to review a final grade report for all students and identify those who need R2T4 calculations based on that review. Both the director and coordinator sign the working documents to indicate that it has been reviewed by both parties. We will continue with this process and will refine as necessary, but we anticipate that this will resolve the issue of calculations not having been performed on students with all F/NP grades at the end of the term.

Categories

Student Financial Aid Subrecipient Monitoring Reporting Significant Deficiency

Other Findings in this Audit

  • 1221345 2025-001
    Material Weakness Repeat
  • 1221347 2025-003
    Material Weakness Repeat
  • 1221348 2025-004
    Material Weakness Repeat
  • 1221349 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.027 ASSISTANCE TO TRIBALLY CONTROLLED COMMUNITY COLLEGES AND UNIVERSITIES $1.84M
84.425 EDUCATION STABILIZATION FUND $1.24M
84.063 FEDERAL PELL GRANT PROGRAM $499,297
84.031 HIGHER EDUCATION INSTITUTIONAL AID $398,719
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $270,836
10.517 TRIBAL COLLEGES EXTENSION PROGRAMS $250,607
10.516 RURAL HEALTH AND SAFETY EDUCATION COMPETITIVE GRANTS $121,019
10.527 NEW BEGINNING FOR TRIBAL STUDENTS $83,160
10.227 1994 INSTITUTIONS RESEARCH PROGRAM $79,082
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $76,492
10.221 TRIBAL COLLEGES EDUCATION EQUITY GRANTS $51,389
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING (INBRE) $49,771
15.820 NATIONAL AND REGIONAL CLIMATE ADAPTATION SCIENCE CENTERS $28,821
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS (FSEOG) $12,566
45.311 NATIVE AMERICAN AND NATIVE HAWAIIAN LIBRARY SERVICES $9,935
12.598 CENTERS FOR ACADEMIC EXCELLENCE $9,582
10.311 BEGINNING FARMER AND RANCHER DEVELOPMENT PROGRAM $2,500
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $104