Finding 43716 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-11-21

AI Summary

  • Core Issue: The University failed to return unearned Title IV funds within the required 45 days after students withdrew.
  • Impacted Requirements: This violates 34 CFR 668.22 regulations regarding timely return of funds.
  • Recommended Follow-Up: Implement regular reviews of withdrawal lists and R2T4 calculations, and ensure experienced staff oversee the process to maintain compliance.

Finding Text

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not return unearned Title IV funds within the 45 days from the determination of the student's withdrawal. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 40 students, 2 students who withdrew during the audit period tested had a total of $5,655 in Title IV funds returned late. Both unofficial withdrawals for Fall 2021 had funds returned in September and October 2022 as the financial aid director caught during the 2021-2022 audit that the funds had not yet been returned. Cause: Implementation of new modular withdrawal regulations and lack of review over individual R2T4 calculations, particularly over unofficial withdrawals Effect: Return of Title IV funds were not performed timely Identification as repeat finding, if applicable: n/a Recommendation: We recommend that the University run a listing of withdrawals after each semester and compare the list of students who had R2T4?s completed to ensure completeness. We further recommend a 0-credit report be run at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4?s are completed timely when required. We recommend an individual in financial aid with the appropriate level of experience periodically review modular students, R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Return of Title IV (R2T4) Calculations Planned Corrective Action: Our process for identifying unofficial withdrawals has been to nm a report through our Workday software to identify students who had unearned credits in a semester at the conclusion of that semester, after the grade due date. We would then reach out to the individual professors of the courses to determine if each student completed the semester or if they had unearned credits because they ceased attending at some point during the semester. If they ceased attending, we would determine if a Return of Title IV (R2T4) Calculation was needed and would complete it if necessary. In preparing for the Al 33 audit, the auditor requested: "If you have online or modular students, please provide a list of students who earned 0 credits or no showed in at least one of the online classes or modules from the registrar." While pulling together the list of students to send to the auditors, we determined that the repo11 we were using to identify unofficial withdrawals did not include students who had No Credit (NC) grades or Incomplete (I) grades. It was only pulling Failed (F) grades. In addition, the report only included students who had received F grades in all the courses for the semester; it did not include students who received 0 credits in one of the modules. The report was corrected and should enable PLNU to identify all the students who need to be reviewed going forward. In addition, we have added to our process instructions to run this report after the grades for module I are due, and after the grades for module 2 are due, rather than at the end of each semester. This will ensure that we catch any unofficial withdrawals in a timelier manner and will allow us to meet the 45-day deadline for any possible returns that must be made. Person Responsible for Corrective Action Plan: Jamie Asche, Director of Financial Aid Anticipated Date of Completion: 11/30/2022

Categories

Internal Control / Segregation of Duties Student Financial Aid Significant Deficiency

Other Findings in this Audit

  • 43717 2022-001
    Significant Deficiency
  • 620158 2022-001
    Significant Deficiency
  • 620159 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $37.65M
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $4.12M
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $3.85M
84.063 Federal Pell Grant Program $3.59M
84.038 Federal Perkins Loan Program $1.74M
84.033 Federal Work-Study Program $570,743
93.264 Nurse Faculty Loan Program (nflp) $415,594
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $385,148
84.007 Federal Supplemental Educational Opportunity Grants $269,190
93.364 Nursing Student Loans $213,445