Finding 1237693 (2026-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2026
Accepted
2026-09-28
Audit: 412634
Auditor: CAPINCROUSE LLC

AI Summary

  • Core Issue: The University failed to return unearned Title IV funds on time for students who withdrew, leading to a material weakness in compliance.
  • Impacted Requirements: Non-compliance with 34 CFR 668.22, resulting in questioned costs totaling $15,522 due to late returns.
  • Recommended Follow-Up: Assign a qualified financial aid staff member to regularly review R2T4 calculations and ensure timely returns to improve internal controls.

Finding Text

Untimely Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants, 84.268 Federal Direct Student Loans Federal Award Identification #: 2025-2026 Financial Aid Year Condition: When students withdrew officially or unofficially during a term, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $15,522 Context: Out of 40 students tested, 2 students who withdrew during the audit period tested did not have unearned Title IV funds originally returned. 1 student had $1,578 in Federal Direct Loans returned in June 2026, 164 days late. 1 student had $3,476 in Pell returned in July 2026, 109 days late. These amounts are included in the questioned costs. As part of a full file review, the University identified 10 additional students who did not meet the 60% attendance mark yet did not have R2T4s performed. All of these were corrected and resulted in $7,389 of Federal Loans and $3,079 of Pell returned in September 2026 as part of the audit process, ranging from 200 to 279 days late, and are therefore included as questioned costs. Cause: This was an oversight by the University resulting from a lack of reliable last date of participation data in the student systems. Until this issue is resolved, the University will be manually reviewing all 0-credit students at the end of each term. Effect: Incorrect amount of unearned Title IV funds returned, returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review modular students R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: Mid-America Christian University (MACU) has conducted a comprehensive audit of all students who earned zero credits during the 2025–2026 academic year to identify any unrecorded unofficial withdrawals and ensure all necessary Return of Title IV (R2T4) calculations were performed. For any identified deficiencies, funds were processed and returned immediately. To ensure ongoing compliance, MACU has established a standardized protocol between Academic Affairs, the Registrar, and the Financial Aid Office to accurately track the Last Date of Participation /LDP: 1. Faculty Grade & LDP Mandate: Academic Affairs has updated grading procedures to require faculty to record the LDP directly into the Jenzabar whenever a student receives a failing grade or incomplete due to non-attendance/non-participation. 2. Automated Reporting: A term exception report identifies all students with zero earned credits or unearned grades across term modules, enabling the Financial Aid team to promptly verify LDP via Canvas and process R2T4 calculations within federal deadlines. 3. Timeline Enforcement: The Financial Aid Office will enforce standard operating procedures to ensure unofficial withdrawal determinations are completed within 30 calendar days following the term end, and any required Title IV returns are executed within 45 calendar days of the withdrawal determination date (34 CFR 668.22). Person Responsible for Corrective Action Plan: Bobbie Spurgeon-Harris, Executive Vice-President and Chief of Staff Anticipated Date of Completion: 09/30/2026

Categories

Student Financial Aid Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1237692 2026-002
    Material Weakness Repeat
  • 1237694 2026-003
    Material Weakness Repeat
  • 1237695 2026-003
    Material Weakness Repeat
  • 1237696 2026-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $20.08M
84.063 FEDERAL PELL GRANT PROGRAM $6.97M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $228,254
84.033 FEDERAL WORK-STUDY PROGRAM $216,846
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $179,835
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $137,678