Finding 512995 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-04
Audit: 330866
Organization: West Shore Community College (MI)

AI Summary

  • Core Issue: The College incorrectly calculated return of funds due to not excluding scheduled breaks of five days or more in the R2T4 calculations for the 2023 fall and 2024 spring terms.
  • Impacted Requirements: Compliance with 34 CFR 668.22(f)(2)(i) regarding the treatment of scheduled breaks in enrollment periods.
  • Recommended Follow-Up: Review R2T4 requirements and establish procedures to ensure accurate term day calculations moving forward.

Finding Text

Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.063 and 84.268; Award Numbers P063P225088 and P268K225088. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. It was noted during our testing of one R2T4 calculation that the College is not excluding the correct number of days for scheduled breaks of five days or more in both the 2023 fall and 2024 spring terms. Thus, calculations performed for the 2023 fall and 2024 spring terms were determined to be inaccurate. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days. View of Responsible Officials. Management concurs with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

Auditor Description of Condition and Effect. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. It was noted during our testing of R2T4 calculations that the College is not excluding the correct number of days for scheduled breaks of five days or more in both the 2023 fall and 2024 spring terms. Thus, all calculations performed for both of these terms were determined to be inaccurate. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Auditor Recommendation. We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days. Corrective Action. The Director of Financial Aid has reviewed the R2T4 requirements in detail and have implemented enhanced procedures to ensure accurate R2T4 calculations moving forward. One of the key steps in the College's corrective action plan is to introduce a more rigorous review process when developing our annual academic calendars. This includes conducting a pre-term audit of the calendar to verify the total number of term days, including the correct designation of non-instructional days, when developing the proposed academic calendar. Once cross-checking against R2T4 requirements has been completed, the Registrar will bring the proposed calendar to the College’s Institutional Effectiveness Team. This group will then serve as an additional review panel and approval body to ensure all term days, including breaks, are accurately reflected to prevent future discrepancies in the R2T4 calculations. Responsible Party. The Dean of Student Services will take primary responsibility for overseeing this process and ensuring accuracy and R2T4 compliance. Anticipated Completion Date. The corrective action plan is already in progress, with full implementation expected by June 30, 2025.

Categories

Special Tests & Provisions Reporting Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 512996 2024-001
    Significant Deficiency
  • 1089437 2024-001
    Significant Deficiency
  • 1089438 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.39M
21.027 Coronavirus State and Local Fiscal Recovery Funds $280,148
84.268 Federal Direct Student Loans $273,099
84.048 Career and Technical Education -- Basic Grants to States $96,128
84.007 Federal Supplemental Educational Opportunity Grants $50,630
84.033 Federal Work-Study Program $47,184