Finding 1240736 (2026-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2026
Accepted
2026-10-20
Audit: 415110
Organization: North Greenville University (SC)
Auditor: CAPINCROUSE LLC

AI Summary

  • Core Issue: R2T4 calculations were often inaccurate and returned late, leading to compliance issues.
  • Impacted Requirements: Violations of 34 CFR 668.22 related to timely and accurate return of Title IV funds.
  • Recommended Follow-Up: Assign an experienced financial aid staff member to regularly review R2T4 calculations for modular students to ensure compliance.

Finding Text

Inaccurate and Late Return of Title IV (R2T4) Funds Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans, 84.063 Federal Pell Grants Federal Award Identification #: 2025-2026 Financial Aid Year Condition: R2T4 calculations were not consistently completed correctly. Criteria: 34 CFR 668.22 Questioned Costs: $5,807 Context: Out of 6 withdrawals tested, 1 R2T4 calculation was inaccurate and 2 were returned late. One student’s Post-Withdrawal Disbursement was calculated using both modules in the term rather than only one. This resulted in an overaward of $907 in Pell. One modular student was incorrectly evaluated as being a withdrawal exemption for both the Fall and Spring terms. This resulted in $4,900 in FDL being both under-returned and late returns. These were corrected during the audit. Cause: This was an oversight by the University. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. 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

Return of Title IV (R2T4) Calculations Planned Corrective Action: The Financial Aid Office (FAO) has reviewed the R2T4 process and implemented additional procedures to strengthen the accuracy and documentation of withdrawal calculations, particularly for students enrolled in module-based programs. The Financial Aid Office (FAO) has implemented the following enhanced procedures: • The internal R2T4 policy document has been reviewed for accuracy to ensure that all required steps are noted. • R2T4 calculations involving module enrollment, withdrawal exemptions, or Post-Withdrawal Disbursements will receive a second-level review before the calculation is finalized and funds are returned to the Department of Education. • The FAO will maintain a tracking process to monitor R2T4 calculations, required return amounts, and return deadlines to ensure that required returns are completed accurately and within the applicable federal timeframe. • The Financial Aid counselors will receive refresher training on R2T4 requirements, with particular emphasis on withdrawals from module-based programs, the 49% withdrawal exemption, Post-Withdrawal Disbursements, and determining which modules and aid must be included in the calculation. The Director of Financial Aid will periodically review a sample of completed R2T4 calculations to verify compliance with federal requirements and the institution's procedures. Any errors identified through this monitoring will be corrected promptly and used to determine whether additional staff training or procedural changes are necessary. Person Responsible for Corrective Action Plan: Cindi Patterson, Director of Financial Aid Anticipated Date of Completion: October 1, 2026

Categories

Student Financial Aid Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 1240733 2026-001
    Material Weakness Repeat
  • 1240734 2026-001
    Material Weakness Repeat
  • 1240735 2026-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $14.41M
84.063 FEDERAL PELL GRANT PROGRAM $4.60M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $122,054
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $120,588
84.033 FEDERAL WORK-STUDY PROGRAM $79,802