Finding Text
2022-006: Special Tests and Provisions – Return of Title IV Funding
Federal Agency:
Department of Education
Federal Program Title:
Student Financial Aid Cluster
Assistance Listing Number:
84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A215801 (March 25, 2021 - August 31, 2027),
P033A215801(July 1, 2021 - August 31, 2027),
P063P213807(March 23, 2021 - August 31, 2027),
P268K223807(January 1, 2021 - July 31, 2043)
Award Period: July 1, 2021 – June 30, 2022
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: Internal Control – 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). Compliance- The financial aid personnel and the accounting department and the management accounting systems of each non-Federal entity must provide for, effective controls over, and accountability for all students the withdraws from the University [2 CFR §668.22].
Condition: The return to Title IV funding calculations performed on students withdrawn from the eligibility sample did not include a control process to review and approve the calculations for accuracy prior to changes being made to the student’s award.
Questioned Costs: None.
Context: During our audit procedures, the calculations that were preformed did not include documentation of the control process to review and approve the calculations prior to changes being made to the student’s award.
Cause: The University must maintain adequate data and documentation, but due to change in management and turnover in office, there was a lack of conveying institutional knowledge and processes.
Effect: The University is not complying with federal requirements of reporting and information-sharing requirements established by the Department of Education.
Repeat Finding: Yes – 2021-004.
Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the documents are readily available for review upon request, including monitoring of students with triggering events that require a return to Title IV calculation to be completed, reviewed, and approved.
Views of Responsible Officials: There is no disagreement with the audit finding.