Finding 1239630 (2025-101)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: The District failed to return Title IV funds on time, risking future funding from the U.S. Department of Education.
  • Impacted Requirements: Noncompliance with federal regulations regarding timely returns of Title IV funds and inadequate internal controls.
  • Recommended Follow-Up: Implement independent reviews of Title IV fund calculations, ensure timely notifications to students, and return funds within the 45-day requirement.

Finding Text

The District did not timely return Title IV funds to the U.S. Department of Education, increasing the risk of reduced or terminated future awards Cluster name: Student Financial Assistance Cluster Assistance Listings number(s) and name(s): 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award number(s) and year(s): P007A240134 July 1, 2024 through June 30, 2025 P033A240134 July 1, 2024 through June 30, 2025 P063P242910 July 1, 2024 through June 30, 2025 P268K252910 July 1, 2024 through June 30, 2025 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions – return of Title IV funds Questioned costs: None Condition Contrary to federal regulations, the District’s Student Financial Aid Office (Office) did not timely return $1,906 of Student Financial Assistance (SFA) Title IV funds to the U.S. Department of Education (ED) for 3 of 45 students tested who withdrew from the District during the period of enrollment in which the student began attendance. Specifically, the Office did not: Include all required institutional charges recorded in the students’ accounts, such as room and board, when calculating the unearned portion of 2 students’ Pell grant awards, resulting in underpayments to ED for $1,690 and $37. Timely notify 1 student, within 45 days, that they were required to return $179 of unearned Pell grant monies to ED. The District notified the student of the required repayment 607 days late. Effect The District’s failure to timely return Title IV funding and the Office’s lack of controls to comply with federal regulations increases the risk that additional Title IV funds could be returned past the 45-day requirement and increases the risk that ED could reduce or terminate future awards of Title IV funds for noncompliance. There were no questioned costs because, after we informed the District of the underpayments, they submitted $1,690 and $216 to ED on June 6, 2026 and July 15, 2026, respectively. The returns were submitted between 363 and 607 days late. Cause The Office’s policies and procedures did not require a second employee to review and approve the return of Title IV funds calculations to verify that the proper amounts were remitted from both the District and the student. In addition, according to Office management, they did not have the appropriate staffing to complete the secondary reviews. Criteria Federal regulations require the return of Title IV funds when a recipient of Title IV grant or loan assistance withdraws from the District during a payment period or period of enrollment in which the recipient began attendance. Specifically, the District must determine the amount of Title IV aid the student earned as of the student’s withdrawal date. If the total amount of Title IV assistance the student earned is less than the amount that was disbursed to the student or on their behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs no later than 45 days after the date the District determined that the student withdrew (34 Code of Federal Regulations [CFR] §668.22[a–j]). In addition, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the District Improve policies and procedures to require an independent employee to review and approve the return of Title IV funds calculations to verify that the proper amounts were remitted from both the District and the student. Perform timely return of Title IV funds calculations for all students who received Title IV funds and subsequently withdrew from the District, ensuring that all institutional charges are included. Notify students who received student financial assistance and subsequently withdrew from the District of any unearned Title IV funds they are required to repay no later than 45 days after the District’s determination that the student withdrew. Initiate returns of the institution’s and student’s portion of Title IV funds to ED no later than 45 days after the date of the District’s determination that the student withdrew. This finding is similar to prior-year finding 2024-001 and was initially reported in fiscal year 2021. Views of responsible officials District management concurs with this finding. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials regarding these recommendations. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

Corrective Action Plan

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Terrance Quest Anticipated completion date: June 30, 2027 The District concurs with the findings and recommendations. The District recognizes the importance of ensuring that Return of Title IV Funds (R2T4) calculations are completed accurately and timely, that all applicable institutional charges are included in the calculations, and that required institutional and student returns and notifications are completed within the federally established timeframes. The District has taken corrective action regarding the specific students identified during the audit and has returned the applicable funds to the U.S. Department of Education. In addition, the Financial Aid Office is implementing enhanced procedures and system controls designed to address the underlying causes of the finding and strengthen ongoing compliance with federal R2T4 requirements. The updated procedures are expected to be implemented in FY2026-2027 and include: 1. Additional withdrawal monitoring and tracking added to the Return of Title IV (R2T4) reporting. 2. Secondary independent review of the calculation prior to the notification that is sent to students. 3. Implementation of internal automation system connected to the student information system to improve accuracy and reduce the risk of errors in the R2T4 calculation. 4. Tracking and monitoring student notifications and returns to meet required deadlines. 5. Ongoing monitoring of R2T4 activities to evaluate new procedures alignment with compliance requirements.

Categories

Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1239618 2025-101
    Material Weakness Repeat
  • 1239619 2025-102
    Material Weakness Repeat
  • 1239620 2025-103
    Material Weakness Repeat
  • 1239621 2025-104
    Material Weakness Repeat
  • 1239622 2025-101
    Material Weakness Repeat
  • 1239623 2025-102
    Material Weakness Repeat
  • 1239624 2025-103
    Material Weakness Repeat
  • 1239625 2025-104
    Material Weakness Repeat
  • 1239626 2025-101
    Material Weakness Repeat
  • 1239627 2025-102
    Material Weakness Repeat
  • 1239628 2025-103
    Material Weakness Repeat
  • 1239629 2025-104
    Material Weakness Repeat
  • 1239631 2025-102
    Material Weakness Repeat
  • 1239632 2025-103
    Material Weakness Repeat
  • 1239633 2025-104
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $11.64M
84.268 FEDERAL DIRECT STUDENT LOANS $1.20M
17.259 WIOA YOUTH ACTIVITIES $576,075
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $526,603
84.031 HIGHER EDUCATION INSTITUTIONAL AID $432,998
84.047 TRIO UPWARD BOUND $376,289
84.425 EDUCATION STABILIZATION FUND $355,784
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $226,251
84.042 TRIO STUDENT SUPPORT SERVICES $224,519
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $183,287
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $154,169
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $96,656
84.033 FEDERAL WORK-STUDY PROGRAM $87,774
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $83,253
17.258 WIOA ADULT PROGRAM $72,396
84.411 EDUCATION INNOVATION AND RESEARCH (FORMERLY INVESTING IN INNOVATION (I3) FUND) $7,189
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $3,098
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $1,502