Finding 388448 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2024-03-28
Audit: 300168
Organization: Colorado Mountain College (CO)

AI Summary

  • Core Issue: The college lacks effective internal controls over the Return of Title IV (R2T4) process, leading to an input error in fund calculations for one student.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) and 34 CFR 668.22(a)(1) regarding internal controls and accurate R2T4 calculations.
  • Recommended Follow-Up: Implement policies and procedures to establish internal controls that ensure compliance with R2T4 requirements and prevent future errors.

Finding Text

Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a 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). In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The determination of the difference is often referred to as Return of Title IV (R2T4) calculations. Condition: There was one out of eighteen students tested where an input error in the Return of Title IV(R2T4) funds included in the calculation resulting in an error. In addition, there was not an observable internal control over the R2T4 process to prevent errors. Questioned Costs: 84.063 – Federal Pell Grant Programs – $132 Context: The institution does not have internal controls in place to ensure compliance with the Return of Title IV compliance requirement. In addition, during the testing of R2T4 funds, we identified one out of eighteen students tested where the College’s manual calculation included an input error resulting in and underpayment of Title IV funds to the Department of Education. Cause: There are no internal controls in place to prevent and detect errors in the R2T4 process in a timely manner. Effect: Errors in the R2T4 process could go undetected or not be identified in a timely manner. Repeat finding: No Recommendation: The college should implement policies and procedures to ensure compliance with Return of Title IV compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the college reevaluate their procedures regarding the return of Title IV funds including the implementation of secondary review of calculations. This would prevent future errors, and provide a greater level of internal control. Additionally, we recommend they review policies regarding the timeliness and accuracy of student enrollment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CMC established a new secondary review procedure to help prevent future errors and provide a greater level of internal control regarding the return of Title IV funds (R2T4). Going forward, after an R2T4 is completed, the Quality Assurance (QA) review will be processed. As part of this review, the Financial Aid and Scholarship Coordinator will be notified that all R2T4’s have been completed for the current week. They will then pull up the spreadsheet of students who had an R2T4 completed and select at random at least 10% of the students on that list to review. In this review they will examine the following data for each of the selected students:  Each class for that semester including the name of the class, the dates the class took place, the credit load of the class, the last date of attendance (LDA) for each class, if the class counts towards the program, if the class was marked as never attended, and if the class should be used in the R2T4.  The Institutional charges to ensure the correct charges were used.  The Days attended vs Total days to ensure that any break of 5 or more days was removed. To document the review, the Financial Aid and Scholarship Coordinator will initial next to each class that they check as they review. The Financial Aid and Scholarship Coordinator will also review that the awards were updated in the Colleague AIDE screen correctly based on the calculation and ensure that any Post-Withdrawal Disbursement (PWD) or return is processed accurately. They will also verify that the Exit counseling request was sent to the student (this is indicated in the CRI screen). Once the review is completed, the Financial Aid and Scholarship Coordinator will initial and date the spreadsheet for the student that they performed the review on. They will then change the color on the spreadsheet tab to indicate that it was reviewed. Name(s) of the contact person(s) responsible for corrective action: Reilly Watanabe, JoAnna Hulett and Janelle Cook Planned completion date for corrective action plan: July 2023

Categories

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 388449 2023-001
    Significant Deficiency
  • 388450 2023-001
    Significant Deficiency
  • 388451 2023-001
    Significant Deficiency
  • 388452 2023-002
    Significant Deficiency
  • 388453 2023-002
    Significant Deficiency
  • 388454 2023-002
    Significant Deficiency
  • 388455 2023-002
    Significant Deficiency
  • 388456 2023-003
    Significant Deficiency
  • 388457 2023-003
    Significant Deficiency
  • 964890 2023-001
    Significant Deficiency
  • 964891 2023-001
    Significant Deficiency
  • 964892 2023-001
    Significant Deficiency
  • 964893 2023-001
    Significant Deficiency
  • 964894 2023-002
    Significant Deficiency
  • 964895 2023-002
    Significant Deficiency
  • 964896 2023-002
    Significant Deficiency
  • 964897 2023-002
    Significant Deficiency
  • 964898 2023-003
    Significant Deficiency
  • 964899 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $3.46M
84.268 Federal Direct Student Loans $2.81M
84.425 (covid-19) Irepo Rural Support Initiative $1.05M
84.425 (covid-19) Colorado Governor's Emergency Education Relief Funds $1.02M
84.425 (covid-19) Higher Educational Emergency Relief Fund-Heerf III-Student Aid $982,962
84.047 Trio Upward Bound $549,458
84.031 Title III-Higher Education Institutional Aid $376,727
21.027 (covid-19) Coronavirus State and Local Fiscal Recovery Funds $343,340
94.002 Americorps Seniots Retired and Senior Volunteer Program $330,082
84.425 (covid-19) Higher Educational Emergency Relief Fund-Heerf III - Msi $327,738
84.042 Trio Student Support Services $250,107
84.048 Career and Technical Education - Basic Grants to States (perkins Const) $211,584
84.048 Career and Technical Education - Basic Grants to States (perkins) $139,897
84.007 Federal Supplemental Educational Opportunity Grants $97,838
10.699 U.s. Forest Service Cmc Partnership-Winter Internship Pilot $91,858
66.951 Environmental Education Grants $71,564
93.575 Child Care Operations Stabilization $63,000
94.017 Americorps Seniors Senior Demonstration Program $43,625
84.033 Federal Work-Study Program $38,897
19.009 Academic Exchange Programs $17,727
84.425 (covid-19) Higher Educational Emergency Relief Fund-Heerf III-Institutional $17,210
93.779 Centers for Medicare and Medicaid Services (cms) Research, Demonstration and Evaluation $14,760
10.351 Rural Business Development Grant $7,423
45.310 Lsta Arpa State Grants $3,428
84.048 Career and Technical Education - Basic Grants to States (perkins E-Sports) $1,779
84.425 (covid-19) Higher Educational Emergency Relief Fund-Heerf II-Institutional $0