Finding 404720 (2023-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-06-29
Audit: 311103
Organization: College Unbound (RI)

AI Summary

  • Core Issue: The College failed to refund Title IV credit balances to one student within the required 14-day timeframe.
  • Impacted Requirements: Compliance with 34 CFR 668.164(h) regarding timely refunds of Title IV funds.
  • Recommended Follow-up: Enhance internal controls to ensure timely identification and processing of credit balances on student accounts.

Finding Text

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than - (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 1 student, out of a sample of 22, that was not refunded credit balances within the required timeframe by 14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2022-009 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Corrective Action Plan: College Unbound hired two new positions, a Controller and a Bursar, who both started on 10/2/23 (the role was previously filled by a single temporary employee). Part of the Bursar’s scope of work is to work with Financial Aid to ensure that credit balances are issued in the required 14-day timeframe. The full time bursar has a solid understanding of the 14-day requirement and is committed to maintaining compliance in this area. Timeline for Implementation of Corrective Action Plan: Corrected. Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO

Categories

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 404721 2023-003
    Significant Deficiency
  • 404722 2023-004
    Material Weakness Repeat
  • 404723 2023-004
    Material Weakness Repeat
  • 404724 2023-005
    Significant Deficiency
  • 404725 2023-006
    Material Weakness Repeat
  • 404726 2023-006
    Material Weakness Repeat
  • 404727 2023-007
    Significant Deficiency Repeat
  • 404728 2023-007
    Significant Deficiency Repeat
  • 404729 2023-008
    Material Weakness Repeat
  • 404730 2023-009
    Significant Deficiency
  • 404731 2023-010
    Significant Deficiency
  • 404732 2023-011
    Significant Deficiency Repeat
  • 404733 2023-011
    Significant Deficiency Repeat
  • 404734 2023-012
    Significant Deficiency
  • 981162 2023-002
    Significant Deficiency Repeat
  • 981163 2023-003
    Significant Deficiency
  • 981164 2023-004
    Material Weakness Repeat
  • 981165 2023-004
    Material Weakness Repeat
  • 981166 2023-005
    Significant Deficiency
  • 981167 2023-006
    Material Weakness Repeat
  • 981168 2023-006
    Material Weakness Repeat
  • 981169 2023-007
    Significant Deficiency Repeat
  • 981170 2023-007
    Significant Deficiency Repeat
  • 981171 2023-008
    Material Weakness Repeat
  • 981172 2023-009
    Significant Deficiency
  • 981173 2023-010
    Significant Deficiency
  • 981174 2023-011
    Significant Deficiency Repeat
  • 981175 2023-011
    Significant Deficiency Repeat
  • 981176 2023-012
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.23M
84.063 Federal Pell Grant Program $1.04M
21.027 Coronavirus State and Local Fiscal Recovery Funds $809,807
84.116 Fund for the Improvement of Postsecondary Education $543,306
84.425 Education Stabilization Fund $324,547
84.007 Federal Supplemental Educational Opportunity Grants $12,170
84.033 Federal Work-Study Program $9,982