FAC Explorer

Finding 370177 (2023-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-22
Audit: 291731
Organization: Clarke University of Dubuque, Iowa (IA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: There is a material weakness in internal controls over the Return of Title IV funds, with no documented process for calculations.
  • Impacted Requirements: Compliance with federal regulations for calculating unearned Title IV assistance is not being met, risking incorrect financial aid returns.
  • Recommended Follow-Up: The University should enhance and document its controls for Return of Title IV calculations to ensure accuracy and compliance.

Finding Text

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Eight instances were identified where there was no documented control over the Return of Title IV calculation. Cause: The University did not have a documented control over all of the Return of Title IV calculations. Effect: Without a secondary review and approval, there is a possibility that the Return of Title IV calculations could be incorrect. Questioned Costs: None Context/Sampling: Of the 16 students in which a Return of Title IV funds were calculated, 3 were tested. There were also 9 additional students that were tested based on a population of all withdrawn students or 46 students. The amount tested was $60,000 of the total population of funds received of $299,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Corrective Action Plan

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Eight instances were identified where there was no documented control over the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained in these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

Categories

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

Other Findings in this Audit

  • 370175 2023-002
    Significant Deficiency Repeat
  • 370176 2023-002
    Significant Deficiency
  • 370178 2023-003
    Material Weakness Repeat
  • 370179 2023-003
    Material Weakness
  • 370180 2023-004
    Significant Deficiency
  • 370181 2023-004
    Significant Deficiency
  • 370182 2023-004
    Significant Deficiency
  • 370183 2023-005
    Significant Deficiency Repeat
  • 370184 2023-005
    Significant Deficiency Repeat
  • 370185 2023-005
    Significant Deficiency Repeat
  • 370186 2023-006
    Significant Deficiency
  • 946617 2023-002
    Significant Deficiency Repeat
  • 946618 2023-002
    Significant Deficiency
  • 946619 2023-003
    Material Weakness Repeat
  • 946620 2023-003
    Material Weakness Repeat
  • 946621 2023-003
    Material Weakness
  • 946622 2023-004
    Significant Deficiency
  • 946623 2023-004
    Significant Deficiency
  • 946624 2023-004
    Significant Deficiency
  • 946625 2023-005
    Significant Deficiency Repeat
  • 946626 2023-005
    Significant Deficiency Repeat
  • 946627 2023-005
    Significant Deficiency Repeat
  • 946628 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.09M
84.063 Federal Pell Grant Program $1.50M
84.031 Higher Education_institutional Aid $834,152
84.038 Federal Perkins Loan Program $435,196
93.264 Nurse Faculty Loan Program (nflp) $273,927
93.364 Nursing Student Loans $261,461
84.007 Federal Supplemental Educational Opportunity Grants $141,948
97.067 Homeland Security Grant Program $118,590
84.033 Federal Work-Study Program $108,266
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $18,779
84.425 Education Stabilization Fund $5,000