FAC Explorer

Finding 384354 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2024-03-25
Audit: 297469
Organization: University of Denver (CO)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The University failed to return Title IV federal funds that were not negotiated within the required 240 days, leading to non-compliance with federal regulations.
  • Impacted Requirements: Non-compliance with 2 CFR part 200 section 200.303 and 34 CFR 688.164 regarding the timely return of unclaimed federal funds.
  • Recommended Follow-Up: Implement a monitoring control for outstanding checks and return the $158,443 in funds older than 240 days to the U.S. Department of Education.

Finding Text

Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Code of Federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party. Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. Questioned costs: $158,443 Context: During our testing, it was noted 69 out of 400 outstanding checks over 240 days old were Title IV federal funds checks that were over the 240-day limit. Cause: The University did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: No Recommendation: CLA recommends that the University review the requirement and implement a control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the University should return the funding to the U.S. Department of Education. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: As of January 2024, the University implemented a monthly process for the coordinated review of stale-dated checks. After the close of each month, the Accountant II and Business Analyst in the Controller’s Office prepares a report of stale-dated checks and sends the report to the Assistant Director of Student Accounts and the Student Accounts Business Analyst in University Financial Services. These staff members identify federal funds to be returned to the Department of Education. The Office of Student Accounts works with the Office of Financial Aid to ensure funds are returned. This process has addressed any backlog of checks, and the monthly process keeps the University current in processing stale-dated checks and returning funds in a timely manner. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Effective immediately.

Categories

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

Other Findings in this Audit

  • 384352 2023-003
    Significant Deficiency
  • 384353 2023-002
    Significant Deficiency
  • 384355 2023-001
    Significant Deficiency
  • 384356 2023-001
    Significant Deficiency
  • 384357 2023-001
    Significant Deficiency
  • 960794 2023-003
    Significant Deficiency
  • 960795 2023-002
    Significant Deficiency
  • 960796 2023-001
    Significant Deficiency
  • 960797 2023-001
    Significant Deficiency
  • 960798 2023-001
    Significant Deficiency
  • 960799 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loan Program $162.59M
84.038 Federal Perkins Loan Program $5.34M
93.658 Foster Care Title IV-E $4.64M
84.063 Federal Pell Grant Program $4.54M
93.859 Biomedical Research and Research Training $2.38M
84.033 Federal Work Study Program $2.04M
93.648 Child Welfare Research Training Or Demonstration $2.04M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.31M
47.074 Biological Sciences $1.26M
84.007 Federal Supplemental Education Opportunity Grant Program $1.24M
93.837 Cardiovascular Diseases Research $1.23M
47.049 Mathematical and Physical Sciences $924,558
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $915,196
47.076 Stem Education (formerly Education and Human Resources) $878,416
93.242 Mental Health Research Grants $871,432
93.732 Mental and Behavioral Health Education and Training Grants $694,403
84.305 Education Research, Development and Dissemination $635,714
93.865 Child Health and Human Development Extramural Research $615,911
84.206 Javits Gifted and Talented Students Education $582,790
93.060 Sexual Risk Avoidance Education $557,690
93.191 Graduate Psychology Education $540,273
47.075 Social, Behavioral, and Economic Sciences $497,488
93.394 Cancer Detection and Diagnosis Research $454,721
47.041 Engineering $428,449
84.327 Special Education Educational Technology Media, and Materials for Individuals with Disabilities $414,160
12.420 Military Medical Research and Development $399,784
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $324,711
93.855 Allergy and Infectious Diseases Research $270,435
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $253,761
20.701 University Transportation Centers Program $222,842
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $204,069
93.307 Minority Health and Health Disparities Research $161,154
97.132 Financial Assistance for Targeted Violence and Terrorism Prevention $149,834
84.324 Research in Special Education $132,815
93.879 Medical Library Assistance $129,009
93.958 Block Grants for Community Mental Health Services $121,186
14.536 Research and Evaluations, Demonstrations, and Data Analysis and Utilization $114,014
47.070 Computer and Information Science and Engineering $101,477
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $100,700
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $100,044
21.008 Low Income Taxpayer Clinics $99,386
93.696 Certified Community Behavioral Health Clinic Expansion Grants $94,962
45.313 Laura Bush 21st Century Librarian Program $90,991
84.326 Special Education Technical Assistance and Dissemination to Improve Services and Results for Children with Disabilities $87,870
12.630 Basic, Applied, and Advanced Research in Science and Engineering $83,820
94.023 Americorps National Service and Civic Engagement Research Competition $69,244
91.005 Priority Grant Competition $61,283
15.946 Cultural Resources Management $57,768
16.830 Girls in the Juvenile Justice System $57,308
93.604 Assistance for Torture Victims $56,686
12.421 Basic Scientific Research $55,137
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $53,106
45.161 Promotion of the Humanities Research $46,155
45.024 Promotion of the Arts Grants to Organizations and Individuals $45,001
15.954 National Park Service Conservation, Protection, Outreach, and Education $44,278
93.838 Lung Diseases Research $42,528
84.379 Teacher Education Assistance for College and Higher Education (teach) Grants $38,979
15.944 Natural Resource Stewardship $36,653
45.312 National Leadership Grants $28,144
47.079 Office of International Science and Engineering $26,210
43.001 Science $25,806
93.696 Pphf Geriatric Education Centers $24,959
10.310 Agriculture and Food Research Initiative (afri) $23,505
93.575 Child Care and Development Block Grant $19,216
93.113 Environmental Health $19,095
93.136 Injury Prevention and Control Research and State and Community Based Programs $14,749
43.001 Science $14,717
15.945 Cooperative Research and Training Programs – Resources of the National Park System $13,855
93.866 Aging Research $11,421
45.160 Promotion of the Humanities Fellowships and Stipends $10,001
16.812 Second Chance Act Reentry Initiative $6,397
15.933 Preservation of Japanese American Confinement Sites $5,416
16.320 Services for Trafficking Victims $4,525
84.016 Undergraduate International Studies and Foreign Language Programs $2,979
93.600 Head Start $2,797
16.825 Smart Prosecution Initiative $1,944
84.184 School Safely National Activities $734
93.172 Human Genome Research $229