Finding 1223966 (2025-005)

Material Weakness Repeat Finding
Requirement
CLN
Questioned Costs
-
Year
2025
Accepted
2026-07-17
Audit: 407363
Organization: Lemoyne-Owen College (TN)

AI Summary

  • Core Issue: Title IV credit balances were not released to students within the required 14 days, affecting compliance with federal regulations.
  • Impacted Requirements: Non-compliance with 34 CFR § 668.164, risking administrative capability and exposing the College to regulatory findings.
  • Recommended Follow-Up: Implement weekly monitoring of credit balances, improve inter-department coordination, and establish automated alerts for timely disbursement.

Finding Text

Finding 2025-005 – Untimely Release of Title IV Credit Balances (Significant Deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.164 (h)(1)-(2), institutions must pay a Title IV credit balance to the student (or parent for a PLUS Loan) no later than 14 calendar days after the balance occurs. Condition – During testing of student account activity, we identified that fourteen (14) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. All refunds were eventually released to the students. Cause – The delays appear to have resulted from insufficient monitoring of aged credit balances on student accounts. Effect – Holding Title IV funds beyond 14 days impact the College’s administrative capability under 34 CFR § 668.16, exposing the College to regulatory findings and required corrective action. Questioned Costs - $0 Repeat Finding – Yes Perspective – Title IV credit balances must be released to students or parents within 14 days of the date the credit balance is created, in accordance with federal cash management requirements. Timely disbursement is a critical control designed to ensure that students receive funds needed to cover educational expenses and to prevent institutions from improperly holding federal funds. During testing, fourteen (14) out of sixty (60) students (23.3%) were identified with untimely refund disbursements, indicating that controls over cash management and refund processing did not consistently operate effectively. Untimely disbursement may result in students not receiving funds when needed and places the College at risk of noncompliance with federal regulations and potential liabilities. Auditor’s Recommendation – The College should implement weekly monitoring of credit balances, improve coordination between departments, and establish system alerts or automated processes. View of Responsible Officials – The College experienced significant staff turnover within the business office. In addition, the College is undergoing conversion to a new Enterprise Resource Planning (ERP) system which affected its ability to complete some functions in a timely manner. The College has engaged two accounting firms to assist with staff training and bring all functions current.

Corrective Action Plan

Finding 2025-005 - Untimely Release of Title IV Credit Balances (Significant Deficiency): Condition - During testing of student account activity, we identified that fourteen (14) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. All refunds were eventually released to the students. Corrertive Action Plan The College experienced significant staff turnover within the business office. In addition, the College is undergoing conversion to a new Enterprise Resource Planning (ERP) system which affected its ability to complete some functions within a timely manner. A new bursar was hired in May 2026. Timely processing of student refunds was emphasized during her training. Going forward, student refunds will be released within 14 days after credit balances are reflected on student accounts." Completion Date - September 30, 2026 Responsible Party - Chief Financial Officer

Categories

Student Financial Aid Subrecipient Monitoring Cash Management Reporting Significant Deficiency

Other Findings in this Audit

  • 1223957 2025-003
    Material Weakness Repeat
  • 1223958 2025-004
    Material Weakness Repeat
  • 1223959 2025-004
    Material Weakness Repeat
  • 1223960 2025-004
    Material Weakness Repeat
  • 1223961 2025-004
    Material Weakness Repeat
  • 1223962 2025-004
    Material Weakness Repeat
  • 1223963 2025-005
    Material Weakness Repeat
  • 1223964 2025-005
    Material Weakness Repeat
  • 1223965 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $3.11M
84.063 FEDERAL PELL GRANT PROGRAM $3.08M
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $440,476
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $327,266
84.120 MINORITY SCIENCE AND ENGINEERING IMPROVEMENT $200,143
84.033 FEDERAL WORK-STUDY PROGRAM $179,650
47.076 EDUCATION AND HUMAN RESOURCES $106,586