Finding 20781 (2022-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2022-10-30
Audit: 27620
Organization: Trevecca Nazarene University (TN)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The College failed to return Title IV funds on time and with accurate calculations when students withdrew, leading to significant compliance issues.
  • Impacted Requirements: Noncompliance with 34 CFR 668.22 regarding timely and accurate R2T4 calculations for withdrawn students.
  • Recommended Follow-Up: Assign an experienced financial aid staff member to regularly review R2T4 processes and collaborate with other departments to ensure compliance with Title IV regulations.

Finding Text

Incorrect and Untimely Return of Title IV (R2T4) Funds Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely due to late dates of determination. Additionally, there were several returns with the wrong information used in the calculation, causing the wrong amounts to be returned to Title IV. Criteria: 34 CFR 668.22 Questioned Costs: $1,042 Context: Out of 35 students tested for timely returns, there were 11 students who had a date of determination beyond 14 days. These delays resulted in 5 students with returns of Title IV funds totaling $10,565 ranging from 12 to 108 days late. Additionally, out of 35 students tested for proper R2T4 calculation, there were 5 students that had an incorrect R2T4 calculation, resulting in the wrong amount of funds returned. The errors included the wrong total number of calendar days, last date of attendance, and amounts actually disbursed. This resulted in $1,559 of unsubsidized loans being returned that were not required to be returned and $1,042 in additional Pell grants that need to be returned by the University. Cause: Due to the complexity of the new modular regulations, turn over in staffing, and delays from other offices, the University was not able to comply with Title IV regulations for timely and accurate returns. Effect: Noncompliance with new R2T4 regulations regarding withdrawals for modular students, late returns to Title IV, and inaccurate amounts returned to Title IV. Identification as repeat finding, if applicable: 2021-001 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. Additionally, we recommend the University work with other University offices to review Title IV regulations for attendance taking schools to work to achieve compliance on the timeliness of returns to Title IV. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Return of Title IV Funds (R2T4) Planned Corrective Action: Monthly meetings have been scheduled for the academic year to review completed R2T4?s. The director of financial aid and director of student financial services are also conducting additional training with staff to go over the areas of non-compliance that occurred. We have met with leadership on campus to address the issues with attendance tracking so that timely return of Title IV funds can be completed. Reminders have been sent to professors on attendance policies and procedures. These reminders include updated training materials. We have developed additional reports that will allow the University to monitor if attendance is being tracked by individual professors. Areas of non-compliance will be reported to the vice president for academic affairs and accreditation for follow up. Person Responsible for Corrective Action Plan: Kevin Reed, Director of Financial Aid, and Kylie Pruitt, Director of Student Financial Services Anticipated Date of Completion: October 15, 2022

Categories

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Material Weakness Reporting

Other Findings in this Audit

  • 20782 2022-001
    Material Weakness Repeat
  • 597223 2022-001
    Material Weakness Repeat
  • 597224 2022-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $30.05M
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $3.01M
84.063 Federal Pell Grant Program $2.98M
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $2.60M
84.038 Federal Perkins Loan Program $1.30M
84.027 Special Education_grants to States $284,916
84.007 Covid-19 Federal Supplemental Educational Opportunity Grants $196,300
84.007 Federal Supplemental Educational Opportunity Grants $168,511
84.033 Federal Work-Study Program $98,121