Finding 30509 (2022-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-12-08
Audit: 27226
Organization: Warner Pacific University (OR)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: There was a significant deficiency in calculating the return of Title IV funds for students, leading to incorrect funding amounts.
  • Impacted Requirements: Compliance with 34 CFR Section 668.22 regarding the percentage of Title IV assistance earned based on student enrollment status.
  • Recommended Follow-Up: Implement a review process for student enrollment status to ensure accurate calculations for full-time and part-time students.

Finding Text

FINDING 2022-002 ? Special Tests and Provisions ? Return of Title IV: Significant Deficiency in Internal Control over Compliance CFDA Number(s) Name of Federal Program or Cluster Federal Award Number Award Year Questioned Costs Various Student Financial Assistance Cluster N/A Year ended May 31, 2022 Known and likely questioned costs were below $25,000, therefore, there are no questioned costs reported. Criteria ? 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is? i. Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student?s withdrawal date, if this date occurs on or before? (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed or the payment period or period of enrollment for a program that is measured in clock hours; or ii. 100 percent, if the student?s withdrawal date occurs after? (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed or the payment period or period of enrollment for a program that is measured in clock hours; or 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context ? A sample of 15 out of a population of approximately 72 federal aid recipient students whom withdrew, dropped out, or enrolled but never attended during the 2021-2022 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origin and Disbursement system. For 2 of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the students. Questioned Costs ? Known and likely questioned costs were below $25,000, therefore, there are no questioned costs reported. Effect ? When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause ? The University incorrectly based calculations on the default status of full-time rather than adjusting the calculation for part-time students. Recommendation ? We recommend the University implement a process to review student enrollment status to ensure funds returned to students appropriately reflect whether they have full-time or part-time status. Views of Responsible Officials and Planned Corrective Actions ? When performing Return of Title 4 (RT24) calculations for PGS students who withdrew early in the term and were receiving Federal Pell Grant, the University reduced the Pell grant to the new enrollment level, but did not code the Colleague system with the revised enrollment level. Also, the University did not update the enrollment level code to match only the number of courses that the student started. The University has corrected all the past R2T4 calculations that were done in error. The University has revised its procedures to prevent this error from reoccurring.

Corrective Action Plan

WARNER PACIFIC UNIVERSITY MANAGEMENT?S VIEWS AND CORRECTIVE ACTION PLAN For the year ended May 31, 2022 As required by OMB Uniform Guidance, we have provided below our response and corrective action plan addressing the findings in the ?Report on Federal Awards in Accordance with the OMB Uniform Guidance? for the year ended May 31, 2022. FINDING 2022-002 ? Special Tests and Provisions ? Return of Title IV: Significant Deficiency in Internal Control over Compliance Cause: The University incorrectly based calculations on the default status of full-time rather than adjusting the calculation for part-time students. Corrective Action: The University has modified its procedures for enrollment status to ensure funds returned to students appropriately reflect whether they have full-time or part-time status. The University calculations for select PGS students who withdrew early in the term and were receiving Federal Pell Grant, were processed in error. Also, the University did not update the enrollment level code to match only the number of courses that the student started. The University has corrected all the past R2T4 calculations that were done in error. The University has revised its procedures to prevent this error from reoccurring. Anticipated date of corrective action: September 30, 2022 Name of contact person responsible for corrective action: Douglas Wade, EVP/CFO

Categories

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 30508 2022-003
    Significant Deficiency
  • 606950 2022-003
    Significant Deficiency
  • 606951 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $6.27M
84.425 Education Stabilization Fund $2.37M
84.063 Federal Pell Grant Program $1.75M
84.038 Federal Perkins Loan Program $445,567
84.007 Federal Supplemental Educational Opportunity Grants $190,989
84.033 Federal Work-Study Program $77,609
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $21,689