Finding Text
FINDING #2024-004 – SPECIAL TESTS AND PROVISIONS: RETURN OF TITLE IV FUNDS
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268
Award Period: July 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(j), An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew.
Condition / Context: During our audit procedures, we noted that all forms for Fall 2024 and Spring 2024 were completed in after the end of each term, outside of the 30 day limit. Additionally, all forms appeared to have used the same drop date, regardless of the students actual drop date determination.
Questioned Costs: None.
Cause: Inadequate controls over the R2T4 process.
Effect: A lack of internal controls can result in noncompliance with provisions of the various programs within the Student Financial Assistance Cluster.
Repeat Finding: Yes.
Recommendation: We recommend the Colleges reinforce their review processes related to student drops and review all activity level controls to ensure compliance with the various requirements of the Student Financial Assistance Cluster.
Corrective Action Plan: Due to a sudden and unanticipated staffing shortage, R2T4 calculations were performed beyond the required timeframe. A staff member has been hired and one of their main tasks is to do R2T4 Calculations. We reached out to the faculty to get the last day of academic related engagement. In cases where we are unable to get the last day of academic related engagement, the federal guidelines allow schools to use the midpoint of the payment period for the R2T4 calculations.
All policies and procedures relating to R2T4 processing have been reviewed and updated, and a review of all prior year calculations will be performed as well, to ensure compliance. Additional staff have been hired and trained in the process, and calculations are being performed. Adequate and trained staff will ensure that all required calculations are performed accurately, and according to required timelines.
In addition, the Financial Aid Office has transitioned from SAM to the Colleague Financial Aid System (starting in 2024-25) which will provide a more automated and integrated process, with enhanced internal controls.