FAC Explorer

Finding 47891 (2022-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2022-12-20
Audit: 53360
Organization: Central Michigan University (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The University has a material weakness in handling Title IV fund returns, leading to discrepancies in withdrawal dates and untimely returns.
  • Impacted Requirements: Federal regulations require accurate return of Title IV funds calculations and timely returns within specified deadlines (45 days for attended, 30 days for non-attended).
  • Recommended Follow-up: Implement controls to ensure timely and accurate returns, update procedures to align with FSA Handbook guidelines, and generate reports to track compliance.

Finding Text

ALN. Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(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 aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.

Categories

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring Material Weakness Reporting

Other Findings in this Audit

  • 47882 2022-001
    Material Weakness Repeat
  • 47883 2022-002
    Material Weakness Repeat
  • 47884 2022-001
    Material Weakness Repeat
  • 47885 2022-002
    Material Weakness Repeat
  • 47886 2022-001
    Material Weakness Repeat
  • 47887 2022-002
    Material Weakness Repeat
  • 47888 2022-001
    Material Weakness Repeat
  • 47889 2022-002
    Material Weakness Repeat
  • 47890 2022-001
    Material Weakness Repeat
  • 47892 2022-001
    Material Weakness Repeat
  • 47893 2022-002
    Material Weakness Repeat
  • 47894 2022-001
    Material Weakness Repeat
  • 47895 2022-002
    Material Weakness Repeat
  • 47896 2022-001
    Material Weakness Repeat
  • 47897 2022-002
    Material Weakness Repeat
  • 50730 2022-001
    Material Weakness Repeat
  • 50731 2022-002
    Material Weakness Repeat
  • 50732 2022-001
    Material Weakness Repeat
  • 50733 2022-002
    Material Weakness Repeat
  • 624324 2022-001
    Material Weakness Repeat
  • 624325 2022-002
    Material Weakness Repeat
  • 624326 2022-001
    Material Weakness Repeat
  • 624327 2022-002
    Material Weakness Repeat
  • 624328 2022-001
    Material Weakness Repeat
  • 624329 2022-002
    Material Weakness Repeat
  • 624330 2022-001
    Material Weakness Repeat
  • 624331 2022-002
    Material Weakness Repeat
  • 624332 2022-001
    Material Weakness Repeat
  • 624333 2022-002
    Material Weakness Repeat
  • 624334 2022-001
    Material Weakness Repeat
  • 624335 2022-002
    Material Weakness Repeat
  • 624336 2022-001
    Material Weakness Repeat
  • 624337 2022-002
    Material Weakness Repeat
  • 624338 2022-001
    Material Weakness Repeat
  • 624339 2022-002
    Material Weakness Repeat
  • 627172 2022-001
    Material Weakness Repeat
  • 627173 2022-002
    Material Weakness Repeat
  • 627174 2022-001
    Material Weakness Repeat
  • 627175 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $28.42M
84.425 Covid-19 - Education Stabilization Fund $19.62M
84.063 Federal Pell Grant Program $17.28M
84.033 Federal Work-Study Program $1.01M
84.007 Federal Supplemental Educational Opportunity Grants $440,613
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $414,624
47.074 Biological Sciences $350,895
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $350,397
93.310 Trans-Nih Research Support $344,955
47.049 Mathematical and Physical Sciences $310,357
84.217 Trio_mcnair Post-Baccalaureate Achievement $229,325
84.326 Special Education_technical Assistance and Dissemination to Improve Services and Results for Children with Disabilities $221,873
84.044 Trio_talent Search $212,503
84.047 Trio_upward Bound $145,721
81.049 Office of Science Financial Assistance Program $100,546
93.575 Child Care and Development Block Grant $97,728
93.859 Biomedical Research and Research Training $90,468
47.078 Polar Programs $73,778
66.951 Environmental Education Grants $71,175
93.865 Child Health and Human Development Extramural Research $65,890
47.075 Social, Behavioral, and Economic Sciences $64,705
66.461 Regional Wetland Program Development Grants $54,355
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $53,422
93.136 Injury Prevention and Control Research and State and Community Based Programs $48,000
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $45,736
93.393 Cancer Cause and Prevention Research $43,042
93.997 Assisted Outpatient Treatment $41,813
43.001 Science $38,336
93.211 Telehealth Programs $36,193
93.866 Aging Research $33,236
11.432 National Oceanic and Atmospheric Administration (noaa) Cooperative Institutes $32,412
93.855 Allergy and Infectious Diseases Research $30,709
11.459 Weather and Air Quality Research $22,237
10.558 Child and Adult Care Food Program $21,169
66.469 Great Lakes Program $18,942
12.RD Bequest: Benchmarking Quantum Enhancement in Science and Technology $18,650
84.305 Education Research, Development and Dissemination $17,328
97.039 Hazard Mitigation Grant $16,363
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $16,031
93.838 Lung Diseases Research $15,877
93.837 Cardiovascular Diseases Research $14,873
15.662 Great Lakes Restoration $14,518
12.630 Basic, Applied, and Advanced Research in Science and Engineering $14,241
93.RD Cog Non-Industry Clinical Trials $14,000
47.041 Engineering $13,224
93.U01 Group Exercise, Training and Fitness (get Fit): Otago Exercise Program $12,751
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $11,606
12.006 National Defense Education Program $11,226
15.637 Migratory Bird Joint Ventures $10,773
45.164 Promotion of the Humanities_public Programs $10,000
15.933 Preservation of Japanese American Confinement Sites $8,705
93.110 Maternal and Child Health Federal Consolidated Programs $8,528
45.310 Grants to States $6,771
93.173 Research Related to Deafness and Communication Disorders $6,752
12.901 Mathematical Sciences Grants Program $6,510
47.079 Office of International Science and Engineering $5,879
47.076 Education and Human Resources $3,700
11.467 Meteorologic and Hydrologic Modernization Development $3,381
11.553 Special Projects $2,080
93.867 Vision Research $1,889
47.050 Geosciences $495
15.608 Fish and Wildlife Management Assistance $23