Finding 524939 (2024-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-28

AI Summary

  • Core Issue: The District failed to comply with Title IV fund return requirements, resulting in errors in 17 out of 40 student cases during R2T4 testing.
  • Impacted Requirements: Non-compliance with 34 CFR 668.22 regarding timely returns of funds and accurate calculations for students who withdraw.
  • Recommended Follow-Up: Implement a second review process for R2T4 calculations to ensure accurate adjustments and timely returns to the Department.

Finding Text

2024 – 001: Return of Title IV Funds Testing Federal Agency: Department of Education Federal Program: Student Federal Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of 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. In accordance with 34 CFR 668.22(b) and (d)(4),the institution must return those funds for which it is responsible under paragraph (a) of this section to the respective title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. An institution does not satisfy this requirement if— (i) The institution's records show that the check was issued more than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 45 days after the date that the institution becomes aware that the student will not or has not begun attendance. Condition: It was noted during our testing of R2T4 calculations that 17 of 40 students selected for R2T4 testing had an instance of non-compliance. Specifically, 12 students had excess returns totaling $2,404; one of those students also should have received a post-withdrawal disbursement of $124; three students had under returns of $22; and one student's return was not received within the 45-day time limit. Questioned Costs: Excess returns exceeded under returns and missed post-withdrawal disbursement. Accordingly, there are not net questioned costs. Context: During our audit procedures, we noted below instances for R2T4 testing: - 1 of the 40 total students' Pell was not returned within the 45 days requirement due to human error. - 16 of the 40 total students' R2T4 was incorrectly calculated. Cause: The District does not have proper second review in place to ensure student awards are properly adjusted based on calculations performed. Effect: The District is not returning the proper amounts to the Department based on the calculations performed. Repeat Finding: Yes, 2023-001. Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Views of Responsible Officials: Management concurs with the finding.

Corrective Action Plan

Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Response to Recommendation: The District acknowledges the importance of adhering to R2T4 requirements and has taken the following actions to address this recommendation: The District adjusted the student samples as notated by auditors. Samples with discrepancies have been recalculated based on R2T4 requirements and correct amounts have been returned to the Department of Education. Verification of corrected R2T4 calculations was provided to auditors. Action taken in response to finding: 1. Consultant Engagement: o A NASFAA-certified consultant with extensive experience as a financial aid director has been hired to assist the R2T4 team during the 2024-2025 aid year. o The consultant will review all R2T4 calculations to ensure compliance and accuracy. Additionally, a secondary staff member is assisting in reviewing all 2024-2025 R2T4 calculations. 2. Training Initiatives o Provided department-wide training on R2T4 policies and procedures. o Delivered in-depth training sessions specifically tailored for the R2T4 team. o The R2T4 team has successfully completed NASFAA’s R2T4 course series to enhance their expertise. 3. Staffing Adjustments o An Accounting Technician under the direction of the District Business Manager will be assigned to Financial Aid to support R2T4 processing and reconciliation to ensure accuracy and compliance. o Additionally, this Accounting Technician will need to have view-only access to all data and reports available in the Student Financial Aid module contained in Colleague in o order to be effective in providing meaningful analysis and reconciliation of student-level detail to summary ledgers and reports contained in the Fiscal Services module of Colleague and other financial reporting tools. 4. Process Improvements o Instruct the R2T4 team to use the Department of Education’s R2T4 worksheet in the COD system instead of the R2T4 module in Colleague. o This change addresses the lack of automation and checks in the Colleague system, which has been a contributing factor to discrepancies. o Financial Aid has reached out and established rapport and protocols with academic and registrar offices to enhance understanding of academic engagement, registration processes, and data fields. o The department has updated the policy and procedures manual, including cheat sheets to clarify points of regulatory interpretation along with El Camino’s data fields to use. 5. System and Workflow Evaluation o Identified that the R2T4 module in Colleague lacks automation or checks and balances to flag manual input discrepancies. o Future plans include exploring system enhancements or alternatives to improve functionality and reduce reliance on manual calculations. o The District has begun evaluating ways to improve the R2T4 reports to help automate this process as much as possible. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: Implementation Timeline:  Consultant Review: Begin immediately, with ongoing review throughout the 2024-2025 aid year; retain consultant services for 2025-2026 aid year.  Training: Complete with Spring 2025 R2T4 calculation, with periodic refresher sessions scheduled on an annual basis.  Staffing Request: The Accounting Technician position will be assigned no later than July 1, 2025. This position shall be filled by existing accounting staff or, if needed, a new employee.  Process Transition: Full transition to the COD system worksheet for R2T4 calculations with the Fall 2024 term R2T4 calculation.  System Evaluation: Initiate and maintain ongoing discussions with IT and software providers, leveraging opportunities from conferences, networking events, and training sessions to explore and implement improvements. Monitoring and Evaluation:  Conduct monthly audits of R2T4 calculations to identify and address errors promptly.  Maintain ongoing collaboration with the consultant to refine processes and implement best practices.  Evaluate the effectiveness of new training and staffing adjustments after six months and report findings.

Categories

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 524940 2024-001
    Material Weakness Repeat
  • 524941 2024-001
    Material Weakness Repeat
  • 524942 2024-001
    Material Weakness Repeat
  • 524943 2024-002
    Material Weakness
  • 524944 2024-002
    Material Weakness
  • 524945 2024-002
    Material Weakness
  • 524946 2024-002
    Material Weakness
  • 1101381 2024-001
    Material Weakness Repeat
  • 1101382 2024-001
    Material Weakness Repeat
  • 1101383 2024-001
    Material Weakness Repeat
  • 1101384 2024-001
    Material Weakness Repeat
  • 1101385 2024-002
    Material Weakness
  • 1101386 2024-002
    Material Weakness
  • 1101387 2024-002
    Material Weakness
  • 1101388 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $29.65M
84.425 Higher Education Emergency Relief Funds (heerf) - Institutional $2.63M
84.268 Federal Direct Student Loans $896,713
84.007 Federal Supplemental Educational Opportunity Grants $810,522
84.048 Career and Technical Education -- Basic Grants to States: Perkins Title I-C $781,078
84.033 Federal Work-Study Program $465,543
59.037 Small Business Development Centers $343,190
84.116 Ecc Warriors Resource Program $217,918
84.116 Warriors Stem Industry Program $187,981
93.558 Temporary Assistance for Needy Families $186,263
84.423 Center for Collaborative Education $154,610
84.002 Workforce Innovation and Opportunity Act, Title II (wioa) $136,607
11.611 Manufacturing Extension Partnership $78,980
84.031 Wings-Warrior Initiative $77,408
12.600 California Advanced Defense Ecosystems & National Consortia Effort (cadence) $59,017
47.076 Replication of Cohort-Based Computer Science Bachelor's Degree Model $56,623
64.117 Veterans Education $48,573
12.617 California Advanced Supply Chain Analysis and Diversification Effort Phase II (cascade Ii) Project $47,489
10.580 Calfresh Snap Outreach Program (cfo) $37,717
93.658 Foster and Kinship Care Education Program $35,539
94.006 Americorps State and National 94.006 $4,561
93.778 Medi-Cal Administrative Activities $1,039