Finding 33996 (2022-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2022-11-15
Audit: 34177
Organization: University of the Southwest (NM)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The University failed to accurately identify students needing R2T4 funds returned after withdrawals, leading to incorrect returns.
  • Impacted Requirements: Noncompliance with 34 CFR 668.22 regulations for timely and accurate R2T4 calculations.
  • Recommended Follow-Up: Assign a financial aid staff member to regularly review R2T4 calculations for modular students to ensure compliance.

Finding Text

Incorrect and Untimely Return of Title IV (R2T4) Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students in a modular program withdrew either officially or unofficially, the University incorrectly identified students who needed an R2T4 completed. Criteria: 34 CFR 668.22 Questioned Costs: $7,969 Context: Out of 28 students tested for accurate and timely returns, there were 6 students who had either earned failing grades or met an exemption under the new R2T4 modular withdraw regulations and did not require an R2T4 to be completed. This resulted in the University returning $2,573 in Pell and $8,172 in Federal Direct Loans to the Department of Education (ED) even though the students were eligible for those funds. There were an additional 2 students that had wrong amounts calculated for the R2T4 which led to $4,583 that should have been returned to ED and 1 student with a late return totaling $3,356. All these students were corrected during the audit. Cause: Due to the complexity of the new modular regulations 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: 2021-003 Recommendation: We recommend an individual in financial aid 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

Incorrect and Untimely Return of Title IV (R2T4) Funds Planned Corrective Action: The Financial Aid Office reviewed the new modular regulations and guidance again as it was identified that exemption(s) were missed in the initial review. The team updated the 2021 NASFAA R2T4 decision tree with notes breaking down the complexity of the new modular regulations and how they apply to our modules/programs. The unofficial withdrawal list for the academic year was re-requested from the registrar?s office and reviewed. Students that met exemption were awarded funds back, recalculated if needed, and processed. Although the Financial Aid Office did implement changes on identifying unofficial withdraws (students were identified) from the prior year finding, the complexity of the modular regulations impacted the finding for 2022. A review of each student?s module will be performed (Executive Director of Financial Aid / Lead Director) and then reviewed and processed by staff member (Financial Aid Director). The final determination list will be compared to the R2T4?s processed. Person Responsible for Corrective Action Plan: Sandy Wilkinson, Executive Director of Financial Aid Anticipated Date of Completion: Implemented

Categories

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

Other Findings in this Audit

  • 33997 2022-001
    Material Weakness Repeat
  • 610438 2022-001
    Material Weakness Repeat
  • 610439 2022-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $9.19M
84.063 Federal Pell Grant Program $1.19M
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $691,932
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $689,310
84.425 Covid-19 Education Stabilization Fund Heerf - Minority Serving Institutions $84,039
84.007 Federal Supplemental Educational Opportunity Grants $63,029
84.033 Federal Work-Study Program $35,320