Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program; Federal Direct Student Loan Program
Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2021-008
Criteria - 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 assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section, and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a postwithdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - Our audit procedures identified an instance where the School could not locate evidence that the required Return to Title IV Funds (R2T4) calculation under federal regulation was completed. The total assistance disbursed to this student was $5,125.
Questioned Costs - $5,125
Identification of How Questioned Costs Were Computed - As of the date of the report, the School has not completed the required R2T4 calculation. Therefore, the questioned cost is equal to the total assistance disbursed to this student.
Context - During our testing, we noted that for one student tested, management could not locate evidence that an R2T4 calculation was performed as required by federal regulations and the proper amount of assistance was returned.
Cause and Effect - The School does not have a process in place to ensure that all required R2T4 calculations under federal regulations are performed accurately and on a timely basis and that all funds are returned within the required time frame.
The lack of a process to ensure that all required R2T4 calculations under federal regulations are performed accurately and timely results in noncompliance with federal regulations.
Recommendation - We recommend management implement processes and controls to ensure that all required R2T4 calculations under federal regulations are performed accurately and on a timely basis. Such calculations should be reviewed by an individual other than the preparer, and contemporaneous evidence of such a review should be maintained.
Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. This third party processor is adequately skilled to complete Return of Title IV calculations and includes an established review process for quality control. All documentation will be maintained.