Finding 1241395 (2026-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2026
Accepted
2026-10-30
Audit: 415509
Organization: St. Olaf College (MN)

AI Summary

  • Core Issue: The College incorrectly calculated the return of Title IV funds for students who withdrew, leading to incorrect amounts returned to the U.S. Department of Education.
  • Impacted Requirements: Title IV regulations mandate accurate calculations of earned assistance and timely returns within 45 days of withdrawal determination.
  • Recommended Follow-Up: Update Title IV policies, ensure correct term dates are used, and implement a formal review process for calculations to prevent future errors.

Finding Text

Significant Deficiency – Return of Title IV funds Program: Student Financial Assistance Cluster – Federal Direct Loans and Pell Grants Federal Agency: U.S. Department of Education Assistance Listing Number (ALN): 84.268 and 84.063 Federal Award Identification Number: Various Federal Award Year: June 30, 2026 Criteria: Title IV regulations (34 CFR 668.22) require that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with the regulations. An institution must then return the unearned portion of grants or loans to the Title IV program as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Condition/Context: 2 of the 2 students in the sample selected for testing that required a return of Title IV funds had an amount returned by the College that was incorrect due to an incorrect number of days for the term being used in the R2T4 calculation. For the fall term, the College incorrectly omitted 2 break days, and for the spring term the College used an incorrect end of term date that was 7 days earlier than the actual end of period per the academic calendar. The student from the fall term had $18 too much returned and the student from the spring term had $50 less returned than required, both of Federal Direct Unsubsidized Loans. The College’s controls over the term dates input and R2T4 calculation reviews did not detect the errors. The sample was not a statistically valid sample. Upon learning of these exceptions the College corrected the days used in the calculation for the 2 students noted above and the auditor viewed the corrected R2T4 calculations, student accounts and COD screen prints. The College performed a review of all other withdrawn students noting an additional 7 students impacted from each term. For the fall term an additional $70 too much was returned ($8 Direct Loans and $62 Pell Grants). For the spring term an additional $434 ($220 Direct Loans and $214 Pell) was required to be returned. The College corrected these amounts for all but 1 student ($3 direct loans). The auditor viewed the corrected R2T4 calculations, student accounts and COD screen prints for the 13 students. Cause: Turnover in the financial aid office resulted in the shift the responsibilities between staff and an ineffective informal review. Effect: The College returned incorrect amounts to students and/or the U.S. Department of Education (ED), and they were in possession of funds belonging to the student and/or ED for more than 45 days. Questioned Costs: The auditor’s exceptions were netted for a total of $32 Federal Direct Loans ALN 84.268 to be returned. The College’s additional students noted were netted for a total of $212 Federal Direct Loans ALN 84.268 and $152 Pell ALN 84.063 to be returned. Recommendation: The College should update its return of Title IV policies and procedures to ensure that the dates used for terms and breaks are correct and implement a more formal review of calculations. Management's Response: Management agrees with the finding. Management considers this to be an isolated incident that will not re-occur in future years. Since discovering this error in the 25-26 Academic Year, three staff members have reviewed the 26-27 Academic Calendar to ensure that start dates, end dates and breaks are correctly entered into PowerFAIDS. Additionally, the staff member who managed this process in the 25-26 Academic Year is no longer employed by the College. A new staff member will be responsible for this process and will receive supplemental training to ensure knowledge and accuracy.

Corrective Action Plan

Finding 2026-001: Significant Deficiency – Return of Title IV Funds Program: Student Financial Assistance Cluster – Federal Direct Loans and Pell Grants Assistance Listing Number (ALN): 84.268 and 84.063 Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2026 Condition: 2 of the 2 students in the sample selected that required a return of Title IV funds had an amount returned by the College that was incorrect due to an incorrect number of days for the term being used in the R2T4 calculation. For the fall term, the College incorrectly omitted 2 break days, and for the spring term the College used an incorrect end of term date that was 7 days earlier than the actual end of period per the academic calendar. The student from the fall term had $18 too much and the student from the spring term had $50 less returned than required, both of Federal Direct Unsubsidized Loans. The College’s controls over the term dates input and R2T4 calculation reviews did not detect the errors. The sample was not a statistically valid sample. Upon learning of these exceptions the College corrected the days used in the calculation for the 2 students noted above and the auditor viewed the corrected R2T4 calculations, student accounts and COD screen prints. The College performed a review of all other withdrawn students noting an additional 7 students impacted from each term. For the fall term an additional $70 too much was returned ($8 Direct Loans and $62 Pell Grants). For the spring term an additional $434 ($220 Direct Loans and $214 Pell) was required to be returned. The College corrected these amounts for all but 1 student ($3 direct loans). The auditor viewed the corrected R2T4 calculations, student accounts and COD screen prints for the 13 students. Corrective Action Plan Management agrees with the finding and considers this to be an isolated incident that will not re-occur in future years. Since discovering this error in the 25-26 Academic Year, three staff members have reviewed the 26-27 Academic Calendar to ensure that start dates, end dates and breaks are correctly entered into PowerFAIDS. Additionally, the staff member who managed this process in the 25-26 Academic Year is no longer employed by the College. A new staff member will be responsible for this process and will receive supplemental training to ensure knowledge and accuracy. Completion Date: September 30, 2026 Name(s) of Contact Person(s) Responsible for Corrective Action: Nathan Engle, Controller Email: Engle1@stolaf.com

Categories

Student Financial Aid

Other Findings in this Audit

  • 1241393 2026-001
    Material Weakness Repeat
  • 1241394 2026-002
    Material Weakness Repeat
  • 1241396 2026-002
    Material Weakness Repeat
  • 1241397 2026-002
    Material Weakness Repeat
  • 1241398 2026-002
    Material Weakness Repeat
  • 1241399 2026-002
    Material Weakness Repeat
  • 1241400 2026-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $9.77M
84.063 FEDERAL PELL GRANT PROGRAM $4.13M
84.047 TRIO UPWARD BOUND $867,245
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $688,098
84.033 FEDERAL WORK-STUDY PROGRAM $444,201
84.044 TRIO TALENT SEARCH $433,499
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $351,409
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $321,514
84.042 TRIO STUDENT SUPPORT SERVICES $299,773
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $180,589
47.074 BIOLOGICAL SCIENCES $175,339
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $146,320
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $140,955
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $57,768
47.050 GEOSCIENCES $35,017
19.009 ACADEMIC EXCHANGE PROGRAMS - UNDERGRADUATE PROGRAMS $29,605
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $17,636
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $12,831
93.364 NURSING STUDENT LOANS $3,593