Finding 1240257 (2025-008)

Material Weakness Repeat Finding
Requirement
CELN
Questioned Costs
-
Year
2025
Accepted
2026-10-10

AI Summary

  • Core Issue: The University failed to return unearned Title IV funds for three students within the required 45 days and lacked sufficient documentation for a fourth student.
  • Impacted Requirements: Noncompliance with federal regulations (34 CFR § 668.22 and § 668.24) regarding timely returns and documentation for Title IV funds.
  • Recommended Follow-Up: Strengthen internal controls and procedures to ensure timely R2T4 calculations and maintain complete supporting documentation for compliance.

Finding Text

Finding 2025-008 – U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Untimely Return of Title IV Funds and Insufficient Documentation (Material Weakness): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.22 (j), (1) an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Additionally, 34 CFR § 668.24 requires institutions participating in the Title IV programs to establish and maintain records necessary to demonstrate compliance with Title IV program requirements. Such records must be sufficient to support the institution's determination, calculation, and timely return of Title IV funds for students who withdraw. Condition – During testing of the University's compliance with Return of Title IV Funds (R2T4) requirements, we noted exceptions for four (4) students selected for testing. For three (3) students, the University did not return unearned Title IV funds within the required 45-day timeframe. The returns were made after the regulatory deadline. For one (1) additional student, the University did not provide all documentation requested to support the student's R2T4 determination and calculation. As a result, we were unable to determine whether the calculation was accurate, whether the appropriate amount of Title IV funds was returned, or whether any required return was completed within the required timeframe. Cause – The exceptions appear to have resulted from insufficient monitoring and internal controls over the R2T4 process, including procedures to ensure that required returns are identified and processed within the 45-day timeframe and that complete supporting documentation is maintained and readily available for review. Effect – Failure to return unearned Title IV funds within the required timeframe results in noncompliance with federal R2T4 requirements and may expose the University to repayment liabilities and additional regulatory oversight. Effect – (continued) Additionally, failure to maintain sufficient supporting documentation prevents the University from demonstrating compliance with federal requirements and increases the risk that R2T4 calculations, return amounts, and return dates may be inaccurate or unsupported. Questioned Costs – $0 Repeat Finding – Yes Auditor’s Perspective – The exceptions identified demonstrate weaknesses in the University's controls over the timeliness and documentation of the R2T4 process. Three students had confirmed untimely returns, while sufficient documentation was not provided for a fourth student to allow the auditors to determine compliance. Although the documentation exception does not, by itself, establish that an untimely or incorrect return occurred, the absence of sufficient documentation limits the University's ability to demonstrate compliance with federal requirements. Auditor’s Recommendation – The University should strengthen its procedures and internal controls over the Return of Title IV Funds process to ensure that all required R2T4 calculations are completed timely and that unearned Title IV funds are returned within 45 days of the University's determination that a student withdrew. The University should also establish procedures to ensure that complete supporting documentation is maintained for each R2T4 calculation, including the withdrawal determination, withdrawal date, calculation, institutional charges, aid disbursed or that could have been disbursed, return amounts, and evidence supporting the date funds were returned. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.

Corrective Action Plan

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-008 1. Finding Summary The auditor identified three (3) instances in which the University did not return unearned Title IV funds within the required 45-day timeframe following a student's withdrawal, with the return occurring significantly after the institution's date of determination and one (1) instance in which proper supporting documentation was not maintained. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and concurs that the return of unearned Title IV funds must occur within the required regulatory timeframe. The University recognizes the importance of timely Return of Title IV processing and is committed to strengthening internal controls, oversight, and coordination to ensure future compliance. "3. Root Cause Analysis The root cause was the absence of a formal monitoring and tracking process for Return of Title IV (R2T4) obligations, combined with limited supervisory oversight and insufficient coordination between the Office of Financial Aid, the Business Office, and Student Retention. These factors resulted in delayed identification of withdrawals and untimely processing ofrequired Title IV fund returns. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring. Description of Corrective Actions To address this finding and prevent recurrence, the University has centralized oversight of the Return of Title IV (R2T4) process by assigning responsibility to the Director of Financial Aid and implementing a formal tracking and monitoring system to ensure all returns are completed within the required 45-day timeframe. The Director of Financial Aid now collaborates with Student Retention to receive prompt notification of student withdrawals. Once funds are removed from the student account for R2T4, the Business Office returns the funds within 3 days. In addition, supervisory review procedures have been established to verify the accuracy and timeliness ofR2T4 calculations and returns, strengthening internal controls and ensuring ongoing compliance with federal regulations. Implementing the revised process has been delayed due to personnel changes. Additionally, the University has contracted with Blue Icon Advisors, a National Association of Student Financial Aid Administrators' financial aid consulting service, to review the R2T4 process and assist with implementation. 5. Risk Mitigation (Required - Even if Disagreeing) The University recognizes the importance of proactively managing regulatory risk related to the Return of Title IV process. The corrective actions implemented are intended to improve the timely identification of student withdrawals, strengthen oversight ofR2T4 calculations and returns, and enhance coordination among responsible offices, thereby reducing the risk of delayed returns, regulatory exposure, and future audit findings. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: D Yes ~ No • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented ~ Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will ensure ongoing compliance by conducting routine internal reviews of Return of Title IV activity, including verification of withdrawal notifications, calculation dates, and return confirmations. R2T4 tracking reports and supervisory oversight will be used to monitor timeliness and accuracy, and procedures will be reinforced through continued staff training and management review to support long-term sustainability.

Categories

Student Financial Aid Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness Reporting

Other Findings in this Audit

  • 1240228 2025-003
    Material Weakness Repeat
  • 1240229 2025-003
    Material Weakness Repeat
  • 1240230 2025-003
    Material Weakness Repeat
  • 1240231 2025-003
    Material Weakness Repeat
  • 1240232 2025-003
    Material Weakness Repeat
  • 1240233 2025-003
    Material Weakness Repeat
  • 1240234 2025-003
    Material Weakness Repeat
  • 1240235 2025-003
    Material Weakness Repeat
  • 1240236 2025-003
    Material Weakness Repeat
  • 1240237 2025-003
    Material Weakness Repeat
  • 1240238 2025-003
    Material Weakness Repeat
  • 1240239 2025-003
    Material Weakness Repeat
  • 1240240 2025-003
    Material Weakness Repeat
  • 1240241 2025-003
    Material Weakness Repeat
  • 1240242 2025-003
    Material Weakness Repeat
  • 1240243 2025-003
    Material Weakness Repeat
  • 1240244 2025-004
    Material Weakness Repeat
  • 1240245 2025-005
    Material Weakness Repeat
  • 1240246 2025-006
    Material Weakness Repeat
  • 1240247 2025-006
    Material Weakness Repeat
  • 1240248 2025-006
    Material Weakness Repeat
  • 1240249 2025-006
    Material Weakness Repeat
  • 1240250 2025-007
    Material Weakness Repeat
  • 1240251 2025-007
    Material Weakness Repeat
  • 1240252 2025-007
    Material Weakness Repeat
  • 1240253 2025-007
    Material Weakness Repeat
  • 1240254 2025-008
    Material Weakness Repeat
  • 1240255 2025-008
    Material Weakness Repeat
  • 1240256 2025-008
    Material Weakness Repeat
  • 1240258 2025-009
    Material Weakness Repeat
  • 1240259 2025-009
    Material Weakness Repeat
  • 1240260 2025-009
    Material Weakness Repeat
  • 1240261 2025-009
    Material Weakness Repeat
  • 1240262 2025-010
    Material Weakness Repeat
  • 1240263 2025-010
    Material Weakness Repeat
  • 1240264 2025-010
    Material Weakness Repeat
  • 1240265 2025-010
    Material Weakness Repeat
  • 1240266 2025-011
    Material Weakness Repeat
  • 1240267 2025-011
    Material Weakness Repeat
  • 1240268 2025-011
    Material Weakness Repeat
  • 1240269 2025-011
    Material Weakness Repeat
  • 1240270 2025-012
    Material Weakness Repeat
  • 1240271 2025-012
    Material Weakness Repeat
  • 1240272 2025-012
    Material Weakness Repeat
  • 1240273 2025-012
    Material Weakness Repeat
  • 1240274 2025-013
    Material Weakness Repeat
  • 1240275 2025-013
    Material Weakness Repeat
  • 1240276 2025-013
    Material Weakness Repeat
  • 1240277 2025-013
    Material Weakness Repeat
  • 1240278 2025-014
    Material Weakness Repeat
  • 1240279 2025-014
    Material Weakness Repeat
  • 1240280 2025-014
    Material Weakness Repeat
  • 1240281 2025-014
    Material Weakness Repeat
  • 1240282 2025-015
    Material Weakness Repeat
  • 1240283 2025-015
    Material Weakness Repeat
  • 1240284 2025-015
    Material Weakness Repeat
  • 1240285 2025-015
    Material Weakness Repeat
  • 1240286 2025-016
    Material Weakness Repeat
  • 1240287 2025-016
    Material Weakness Repeat
  • 1240288 2025-016
    Material Weakness Repeat
  • 1240289 2025-016
    Material Weakness Repeat
  • 1240290 2025-017
    Material Weakness Repeat
  • 1240291 2025-017
    Material Weakness Repeat
  • 1240292 2025-017
    Material Weakness Repeat
  • 1240293 2025-017
    Material Weakness Repeat
  • 1240294 2025-018
    Material Weakness Repeat
  • 1240295 2025-018
    Material Weakness Repeat
  • 1240296 2025-018
    Material Weakness Repeat
  • 1240297 2025-018
    Material Weakness Repeat
  • 1240298 2025-019
    Material Weakness Repeat
  • 1240299 2025-019
    Material Weakness Repeat
  • 1240300 2025-019
    Material Weakness Repeat
  • 1240301 2025-019
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.67M
84.063 FEDERAL PELL GRANT PROGRAM $3.57M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $566,939
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $445,997
93.658 FOSTER CARE_TITLE IV-E $212,366
84.033 FEDERAL WORK-STUDY PROGRAM $88,615
47.076 EDUCATION AND HUMAN RESOURCES $65,481
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $37,012
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $14,994
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $11,071
47.083 INTEGRATIVE ACTIVITIES $4,382