Finding 513051 (2023-006)

Significant Deficiency Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-12-04

AI Summary

  • Core Issue: The College failed to refund student credit balances within the required 14-day timeframe, leading to significant deficiencies in compliance with federal regulations.
  • Impacted Requirements: Noncompliance with 34 CFR 668.164(h)(2) regarding timely disbursement of Title IV funds, specifically Pell Grants and Direct Loans.
  • Recommended Follow-Up: Implement stronger controls and processes to ensure accurate reporting and timely refunds, as outlined in the management's corrective action plan.

Finding Text

Special Tests and Provisions – Disbursements to or on Behalf of Students: Student Financial Assistance Cluster: – AL 84.007, 84,063 and 84.268. US Department of Education Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 668.164(h)(2): Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing over the return of credit balances, the following deficiencies were noted: 27 instances where credit balances were not refunded in the required time frame. 47 instances where refunds were due to students but none were posted in the ledger. 9 instances where the balances refunded to students could not be recalculated. Cause: The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs: None identified. Context : The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 60 students out of 404 students were selected for disbursement testing. Identification as a repeat finding: Not a previous finding. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan. Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Corrective Action Plan

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The following is the procedure that the College will be implementing to ensure that student withdrawal calculations are performed accurately and returned within 30 days: I. The registrar will send a list to financial aid of all students that have dropped by end of day every Thursday of each week. The list will include date of determination (DOD) and last date of attendance (LOA) of each student b. DOD wiII be within 14 days of student LOA 2. Upon receipt of the list financial aid will complete the following for each student: a. Gather student's current ledger card b. Gather student's current Transcript c. Complete a cover sheet which indicated the current loan period of the student. d. Financial aid will send over items to yd patty processor in order for R2t4 calculation to be completed (Campus IVY) no later than Wednesday of the following week by end of business day. 3. Campus IVY will complete the R2T4 3-5 business days upon receipt and conduct the following: a. If a refund is required- campus IVY will schedule the refund, update student account and send to school. b. School (student accounts) will review the refund, update student account and monies will be placed in the operations account and sent back to GS. c. If a refund is not required based on the R2T4 results, Campus IVY will notate the student account. This corrective action plan will allow Community Christian College to complete the drop process for each student within 30 days from LOA.

Categories

Student Financial Aid Special Tests & Provisions Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 513049 2023-004
    Significant Deficiency Repeat
  • 513050 2023-005
    Significant Deficiency Repeat
  • 513052 2023-007
    Significant Deficiency Repeat
  • 513053 2023-004
    Significant Deficiency Repeat
  • 513054 2023-005
    Significant Deficiency Repeat
  • 513055 2023-006
    Significant Deficiency Repeat
  • 513056 2023-007
    Significant Deficiency Repeat
  • 513057 2023-004
    Significant Deficiency
  • 513058 2023-005
    Significant Deficiency
  • 513059 2023-006
    Significant Deficiency
  • 513060 2023-007
    Significant Deficiency
  • 1089491 2023-004
    Significant Deficiency Repeat
  • 1089492 2023-005
    Significant Deficiency Repeat
  • 1089493 2023-006
    Significant Deficiency Repeat
  • 1089494 2023-007
    Significant Deficiency Repeat
  • 1089495 2023-004
    Significant Deficiency Repeat
  • 1089496 2023-005
    Significant Deficiency Repeat
  • 1089497 2023-006
    Significant Deficiency Repeat
  • 1089498 2023-007
    Significant Deficiency Repeat
  • 1089499 2023-004
    Significant Deficiency
  • 1089500 2023-005
    Significant Deficiency
  • 1089501 2023-006
    Significant Deficiency
  • 1089502 2023-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.58M
84.063 Federal Pell Grant Program $1.53M
84.007 Federal Supplemental Educational Opportunity Grants $79,026