Finding 1227344 (2025-008)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-08-19
Audit: 409430
Organization: Wittenberg University (OH)
Auditor: RSM US LLP

AI Summary

  • Core Issue: The institution failed to perform Return of Title IV (R2T4) calculations accurately and on time, affecting compliance with federal regulations.
  • Impacted Requirements: R2T4 calculations must be completed within 45 days of a student's withdrawal, and the amounts returned must be accurate.
  • Recommended Follow-Up: The University should review and improve its processes and controls to ensure timely and accurate R2T4 calculations.

Finding Text

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P268K252023; Award Year: 2025 Criteria: Per 34 CFR §668.22, institutions are required to perform Return of Title IV (R2T4) calculations when a student withdraws and must return any unearned Title IV funds within 45 days of the date the institution determines the student withdrew. Institutions are also required to accurately calculate the amount of aid earned by the student and the amount required to be returned. Condition: The institution did not consistently perform R2T4 calculations during the year. As a result: 1. 3 of the 4 students tested had R2T4 calculations that were performed late, resulting in $14,074 of returned funds outside the required timeframe. 2. Of the R2T4 calculations tested, 4 of 4 students had R2T4 calculations that were performed incorrectly, resulting in $691 of net over returned Title IV aid. The sample was not intended to be, and was not, a statistically valid sample. Cause: Turnover within the financial aid department during the period resulted in a lack of continuity in processes related to identifying withdrawn students and completing R2T4 calculations. Effect: Failure to perform timely and accurate R2T4 calculations resulted in noncompliance with federal regulations. Late returns may subject the institution to increased scrutiny, potential liabilities, and interest assessments. Inaccurate calculations result in improper return amounts, impacting both the U.S. Department of Education and affected students. Questioned Costs: $691 related to inaccurate calculations (over/under-returned aid). Context: The University did not have proper controls in place to complete R2T4 calculations timely or accurately. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure R2T4 calculations are completed accurately and timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Corrective Action Plan

Condition Summary: The institution did not consistently perform R2T4 calculations during the year. As a result: 1. 3 of the 4 students tested had R2T4 calculations that were performed late, resulting in $14,074 of returned funds outside the required timeframe. 2. Of the R2T4 calculations tested, 4 of 4 students had R2T4 calculations that were performed incorrectly, resulting in $691 of net over returned Title IV aid. Management Response / Corrective Action Plan: Management concurs with this finding. Turnover within the Financial Aid office resulted in a breakdown in the process used to identify withdrawn students and timely complete R2T4 calculations. As part of the University's full review of 2025-2026 withdrawal activity, all R2T4 calculations have been recalculated and confirmed for accuracy, and any additional funds due have been returned. Staff previously responsible for this function are no longer employed at the institution, and the engaged consulting firm has assumed interim responsibility for identifying withdrawals and completing R2T4 calculations within the required 45-day period, with a secondary review of every calculation prior to submission. Responsible Party - Raymond Nault, Interim Director of Student Financial Services Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1227309 2025-004
    Material Weakness Repeat
  • 1227310 2025-005
    Material Weakness Repeat
  • 1227311 2025-006
    Material Weakness Repeat
  • 1227312 2025-007
    Material Weakness Repeat
  • 1227313 2025-008
    Material Weakness Repeat
  • 1227314 2025-010
    Material Weakness Repeat
  • 1227315 2025-012
    Material Weakness Repeat
  • 1227316 2025-013
    Material Weakness Repeat
  • 1227317 2025-005
    Material Weakness Repeat
  • 1227318 2025-006
    Material Weakness Repeat
  • 1227319 2025-010
    Material Weakness Repeat
  • 1227320 2025-012
    Material Weakness Repeat
  • 1227321 2025-013
    Material Weakness Repeat
  • 1227322 2025-005
    Material Weakness Repeat
  • 1227323 2025-006
    Material Weakness Repeat
  • 1227324 2025-009
    Material Weakness Repeat
  • 1227325 2025-010
    Material Weakness Repeat
  • 1227326 2025-012
    Material Weakness Repeat
  • 1227327 2025-013
    Material Weakness Repeat
  • 1227328 2025-005
    Material Weakness Repeat
  • 1227329 2025-006
    Material Weakness Repeat
  • 1227330 2025-007
    Material Weakness Repeat
  • 1227331 2025-010
    Material Weakness Repeat
  • 1227332 2025-011
    Material Weakness Repeat
  • 1227333 2025-012
    Material Weakness Repeat
  • 1227334 2025-013
    Material Weakness Repeat
  • 1227335 2025-005
    Material Weakness Repeat
  • 1227336 2025-006
    Material Weakness Repeat
  • 1227337 2025-010
    Material Weakness Repeat
  • 1227338 2025-012
    Material Weakness Repeat
  • 1227339 2025-013
    Material Weakness Repeat
  • 1227340 2025-004
    Material Weakness Repeat
  • 1227341 2025-005
    Material Weakness Repeat
  • 1227342 2025-006
    Material Weakness Repeat
  • 1227343 2025-007
    Material Weakness Repeat
  • 1227345 2025-010
    Material Weakness Repeat
  • 1227346 2025-012
    Material Weakness Repeat
  • 1227347 2025-013
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.42M
84.063 FEDERAL PELL GRANT PROGRAM $2.73M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.52M
84.047 TRIO UPWARD BOUND $371,444
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $246,539
84.033 FEDERAL WORK-STUDY PROGRAM $197,921
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $125,283
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $30,978
84.021 OVERSEAS PROGRAMS - GROUP PROJECTS ABROAD $12,176
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $11,208
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $9,503
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $3,956
43.001 SCIENCE $3,045