Finding 505408 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2024
Accepted
2024-11-12
Audit: 328116
Organization: Claremont McKenna College (CA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The College miscalculated the return of Title IV funds for students who withdrew, leading to incorrect financial assistance amounts.
  • Impacted Requirements: Compliance with 34 CFR Section 668.22 regarding the calculation of earned Title IV funds and the total number of calendar days in a payment period.
  • Recommended Follow-Up: Implement a thorough review process for academic calendars and ensure accurate recalculations of attendance days in internal controls for Title IV fund returns.

Finding Text

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan assistance that has been earned by the student is— (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student’s withdrawal date, if this date occurs on or before— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program that is measured in clock hours; or (ii) 100 percent, if the student’s withdrawal date occurs after— (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or (B) 60 percent of the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. 34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were selected. Student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origin and Disbursement system. For one of the selected students, the amount to be returned was calculated incorrectly. This resulted in an understatement of student financial assistance earned by the student. Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire universe of students who received federal aid and withdrew, dropped out, or enrolled but never attended during the 2023-2024 school year. Using this method, we determined likely questioned costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives the incorrect amount of funding. Cause – The College incorrectly calculated the length of a scheduled break in excess of five days and the College incorrectly calculated the total number of days of class the student attended prior to their withdrawal. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a process by which all academic calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure such breaks are accurately accounted for within the total number of calendar days in a payment period or period of enrollment. Secondly, we recommend the College ensure recalculations of total number of days attended and total number of days within the payment period or period of enrollment are incorporated into its existing internal controls around the reviewer of Return of Title IV calculations. Views of responsible officials and planned corrective actions – The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.

Categories

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions Matching / Level of Effort / Earmarking Significant Deficiency

Other Findings in this Audit

  • 505407 2024-001
    Significant Deficiency
  • 505409 2024-001
    Significant Deficiency
  • 505410 2024-001
    Significant Deficiency
  • 505411 2024-001
    Significant Deficiency
  • 505412 2024-001
    Significant Deficiency
  • 505413 2024-002
    Significant Deficiency
  • 505414 2024-002
    Significant Deficiency
  • 505415 2024-002
    Significant Deficiency
  • 505416 2024-002
    Significant Deficiency
  • 505417 2024-002
    Significant Deficiency
  • 505418 2024-002
    Significant Deficiency
  • 1081849 2024-001
    Significant Deficiency
  • 1081850 2024-001
    Significant Deficiency
  • 1081851 2024-001
    Significant Deficiency
  • 1081852 2024-001
    Significant Deficiency
  • 1081853 2024-001
    Significant Deficiency
  • 1081854 2024-001
    Significant Deficiency
  • 1081855 2024-002
    Significant Deficiency
  • 1081856 2024-002
    Significant Deficiency
  • 1081857 2024-002
    Significant Deficiency
  • 1081858 2024-002
    Significant Deficiency
  • 1081859 2024-002
    Significant Deficiency
  • 1081860 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.16M
84.063 Federal Pell Grant Program $1.46M
47.075 Social, Behavioral, and Economic Sciences $460,749
47.074 Biological Sciences $273,422
84.038 Federal Perkins Loan Program (beginning of the Year) $263,094
84.033 Federal Work-Study Program $208,009
47.049 Mathematical and Physical Sciences $185,622
47.076 Education and Human Resources $135,642
47.070 Computer and Information Science and Engineering $130,659
84.007 Federal Supplemental Educational Opportunity Grants $128,438
47.050 Geosciences $113,860
97.036 Covid-19 Disaster Grants – Public Assistance (presidentially Declared Disaster) $84,489
93.859 Biomedical Research and Research Training $30,144
12.800 Air Force Defense Research Sciences Program $13,396
84.038 Federal Perkins Loan Program (current Year Distribution) $0