Finding 524872 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-28
Audit: 344243
Organization: Cumberland University (TN)
Auditor: Lbmc PC

AI Summary

  • Core Issue: The University failed to return Title IV funds within the required 45-day period after student withdrawals.
  • Impacted Requirements: Compliance with 34 CFR 668.22(j)(1) regarding timely remittance of Title IV funding.
  • Recommended Follow-Up: Implement a supervisory review process for returns to ensure accuracy and timeliness, along with regular meetings to monitor compliance.

Finding Text

Criteria: When a recipient of a 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 grant or loan assistance that the student earned as of the student's withdrawal date and must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew (34 CFR 668.22(j)(1)). Condition: The University’s internal controls did not ensure the timely return of Title IV funding within the 45 day remittance period. Cause: The University had a change in the personnel responsible for remitting the funds to the Department of Education during the reporting period. Effect: The University was not in compliance with the return of Title IV funds within the 45 day requirement. Questioned Costs: N/A Context: Out of 33 students that withdrew during the period of enrollment and received Title IV funds, ten students were selected for testing and identified 3 returns that were not made timely. Our sampling method was not, and was not intended to be statistically valid. Identification as a repeat finding, if applicable: Not applicable Recommendation: We recommend that a supervisor of the individual processing the return review all amounts being returned to verify the amounts match the approved RT24 form and that the remittance is made to the Department of Education on a timely basis. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the untimely return of Title IV funds. The University has updated its process for managing Return of Title IV funds which includes a weekly review by the Assistant Director of Financial Aid for performing calculations and processing returns, meetings between the Associate Director and Executive Director to review the prior week’s calculations and returns and completion of checklists to document the completion of the returns.

Corrective Action Plan

Finding Summary: When a recipient of a 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 grant or loan assistance the student earned as of the student’s withdrawal date and must return the amount of Title IV funds for which it was responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew (34 CFR 668.22(j)(1)). Annual Single Audit review of Return to Title IV (R2T4) funds found that the return of federal funds was outside the required window. All necessary funds were returned during the 23-24 funding period. While R2T4 calculations were performed within the required time limit, there were three total students with returns that were outside the return window for the 23-24 Academic Year. Corrective Action Plan (CAP): The Associate Director of Financial Aid will be the primary staff member responsible for the R2T4 calculations and returns. If they are unavailable in a given week, the Executive Director will perform the weekly calculations needed. To ensure that the calculations and returns are completed within federal guidelines, the Associate Director will block 2-4 hours at the beginning of each week of the semester to review the prior week’s withdrawals and perform all necessary calculations and returns. At the end of each week, the Associate Director and the Executive Director will meet to review the prior week’s calculations and returns to ensure all returns have been processed through the Department of Education Common Origination and Disbursement (COD) website. A checklist has been created with all the necessary steps for each return, with a sign-off and documentation required to be attached as proof of completion. Anticipated Completion Date: The procedures will be implemented for the 2024-2025 Financial Aid Year. Responsible Parties: Beatrice LaChance

Categories

Reporting Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 524873 2024-001
    Significant Deficiency
  • 524874 2024-001
    Significant Deficiency
  • 524875 2024-001
    Significant Deficiency
  • 1101314 2024-001
    Significant Deficiency
  • 1101315 2024-001
    Significant Deficiency
  • 1101316 2024-001
    Significant Deficiency
  • 1101317 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.81M
84.063 Federal Pell Grant Program $4.20M
93.493 Congressional Directives $551,771
89.003 National Historical Publications and Records Grants $148,942
84.007 Federal Supplemental Educational Opportunity Grants $115,161
84.033 Federal Work-Study Program $65,891