Finding 391641 (2023-001)

Audit Finding Reference Number Questioned Costs 2023-001 - Return of Title IV Funds $17,509 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (SEOG) Federal Award Year June 30, 2023 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria The 2 CFR Part 200, Compliance Supplement, Part III Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. In addition, when a student does not begin attendance, all Title IV assistance must be returned. A student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Conditions and Context During my audit, I noted the six (6) students out of nine (9) students tested in which the University was unable to document the last date of attendance for each of the students’ enrolled courses, document if the student participated in any academic related activity or document if the student ever attended class. This resulted in $17,509 in Title IV funds being remitted to students whose enrollment could not be verified. Cause The University failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $17,509. SEOG $ 400 PELL 6,465 Direct Loans 10,644 Total $17,509 Effect The University has not complied with Title IV regulations that specify a student is considered to have not begun attendance if the institution is unable to document the student’s attendance at any class. Proper attendance and/or participation in academic related activity documentation was not maintained. Repeat Finding Yes, See 2022-001. Recommendation I recommend that management adhere to established procedures to ensure attendance and/or participation in academic related activity is properly documented. Management Response To address and eliminate the prior audit finding related to Return of Title IV Funds, Academic Affairs and Records and Registration have been working closely with, and to train and educate Deans and Faculty on the Federal Regulations and Guidelines. Internal controls focused on monitoring, documenting, electronically reporting, follow-up reviewing and reporting of students’ last date of attendance and academic related activity have been implemented. The Registrar Office will work with the comparable offices at the consortia universities to implement reporting requirements for timely notification and documentation of withdrawals and/or no-shows to avoid repeat findings. Controls are being tightened between Academic Affairs, the Office of Records and Registration and the Office of Financial Aid & Scholarships.