Finding 520298 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-27
Audit: 340029
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The District failed to return Title IV funds within the required 45 days for one student and miscalculated returns for three others.
  • Impacted Requirements: Noncompliance with 34 CFR 668.173(b) and OMB Compliance Supplement regarding timely fund returns and accurate calculations.
  • Recommended Follow-Up: Review and strengthen policies and internal controls for Return to Title IV calculations to ensure compliance and accuracy.

Finding Text

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period 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 the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Corrective Action Plan

The District and its Financial Aid department will continue to review and enhance the workflow and procedures of Return to Title IV. The goal of these efforts has been to meet the compliance requirements of Return to Title IV. The District has developed a schedule with specific dates per term for when calculations will be completed, when requests will be made to Accounting to return the District portion of funds within 45 days, and provide ample timelines that can ensure funds get returned within compliance. The District has included the various department areas and staff that are involved in the process to ensure the schedule is consistent and that the funds are returned in the appropriate time frame. The Financial Aid department will continue to meliorate the task of the Return to Title IV calculations. This task is a work function of the Financial Aid Coordinator position. While staff has been trained to perform this function, the District is currently in recruitment to fill the Financial Aid Coordinator position. While the Coordinator will be expected to perform the calculations, they will be submitted to the Director of Financial Aid for review and to ensure accuracy.

Categories

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 520299 2024-001
    Significant Deficiency
  • 520300 2024-001
    Significant Deficiency
  • 520301 2024-001
    Significant Deficiency
  • 520302 2024-001
    Significant Deficiency
  • 520303 2024-001
    Significant Deficiency
  • 520304 2024-001
    Significant Deficiency
  • 520305 2024-002
    Significant Deficiency
  • 520306 2024-002
    Significant Deficiency
  • 520307 2024-002
    Significant Deficiency
  • 520308 2024-002
    Significant Deficiency
  • 520309 2024-002
    Significant Deficiency
  • 520310 2024-002
    Significant Deficiency
  • 520311 2024-002
    Significant Deficiency
  • 520312 2024-003
    Significant Deficiency
  • 520313 2024-003
    Significant Deficiency
  • 520314 2024-003
    Significant Deficiency
  • 520315 2024-003
    Significant Deficiency
  • 520316 2024-003
    Significant Deficiency
  • 520317 2024-003
    Significant Deficiency
  • 520318 2024-003
    Significant Deficiency
  • 1096740 2024-001
    Significant Deficiency
  • 1096741 2024-001
    Significant Deficiency
  • 1096742 2024-001
    Significant Deficiency
  • 1096743 2024-001
    Significant Deficiency
  • 1096744 2024-001
    Significant Deficiency
  • 1096745 2024-001
    Significant Deficiency
  • 1096746 2024-001
    Significant Deficiency
  • 1096747 2024-002
    Significant Deficiency
  • 1096748 2024-002
    Significant Deficiency
  • 1096749 2024-002
    Significant Deficiency
  • 1096750 2024-002
    Significant Deficiency
  • 1096751 2024-002
    Significant Deficiency
  • 1096752 2024-002
    Significant Deficiency
  • 1096753 2024-002
    Significant Deficiency
  • 1096754 2024-003
    Significant Deficiency
  • 1096755 2024-003
    Significant Deficiency
  • 1096756 2024-003
    Significant Deficiency
  • 1096757 2024-003
    Significant Deficiency
  • 1096758 2024-003
    Significant Deficiency
  • 1096759 2024-003
    Significant Deficiency
  • 1096760 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $4.16M
84.425 Education Stabilization Fund $3.18M
84.048 Career and Technical Education -- Basic Grants to States $810,003
84.031 Higher Education Institutional Aid $712,259
84.268 Federal Direct Student Loans $636,359
84.047 Trio Upward Bound $336,715
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $212,968
10.665 Schools and Roads - Grants to States $92,672
84.007 Federal Supplemental Educational Opportunity Grants $47,576
84.063 Federal Pell Grant Program $38,045
93.558 Temporary Assistance for Needy Families $23,113
84.033 Federal Work-Study Program $15,373
64.116 Veteran Readiness and Employment $836