Finding Text
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.