Finding 546925 (2024-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351293
Organization: Urban College of Boston (MA)

AI Summary

  • Core Issue: The College failed to refund Title IV credit balances to 29 students within the required 14-day timeframe, violating federal regulations.
  • Impacted Requirements: Non-compliance with 34 CFR 668.164(h) regarding timely refunds of Title IV funds, affecting 65.9% of students with credit balances.
  • Recommended Follow-Up: Enhance procedures for identifying credit balances and provide training for staff on compliance with Title IV regulations.

Finding Text

Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 29 students, out of a sample of 60, that were not refunded credit balances within the required timeframe by 8-251 days. Cause The College failed to identify and return Title IV credit balances within required timeframe due to lack of procedures and knowledge of compliance requirements over Student Financial Assistance requirements within business office. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 44 students, or 73% of our sample, had credit balances caused by financial aid. Of these 44 students, 29 students’ credit balances caused by Title IV funds were not refunded within the required time frame (65.9% of students who had credit balances). The remaining 15 students had credit balances as a result of Title IV aid, which were returned within the required time frame. Identification as a Repeat Finding, if applicable See finding 2023-001 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. Moreover, the College should provide training to employees responsible for processing such information over student accounts to ensure personnel have adequate knowledge in the related rules and regulations. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Corrective Action Plan

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of weak procedures and lack of knowledge from our Business office of Title IV requirements involving the handling of Title IV credit balances. In April 2024 after the 2023 audit, we identified weaknesses in Title IV credit balance process. It was also discovered during the 2023 audit review that not all our Business Office employees understood the federal regulation on Title IV refunds and the 14-day rule. When processes were reviewed and updated, the financial aid and business office staff went through coaching and training. Unfortunately, these 2023-2024 credit balance findings occurred prior to the implementation of these new processes from the results of the 2022-2023 audit. Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. Process changes include Global FAS providing UCB with a daily check register report of all student disbursements. Through the Disbursement process, UCB must first process all check registers, reconcile student billing, and identify and process student credit balances before funds can be drawn down from the Common Origination and Disbursement System (COD). The UCB Business Office commits to processing check registers within 7 business days and providing the Cash Monitoring report to Global FAS so funds can be released and deposited into the Federal Funds Account. The Business Office also conducts a weekly credit balance review in the event adjustments were made to a student’s account that may have created a credit. These updated processes will ensure student refunds are processed within the 14-day federal regulation. The Director of Student Financial Services is also conducting a twice of month Balance Report review to identify any credit balances on students accounts to determine if they are within or outside of the 14 days and reporting back to the Chief Finance Officer if any discrepancies are discovered. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

Categories

Student Financial Aid

Other Findings in this Audit

  • 546926 2024-001
    Material Weakness Repeat
  • 546927 2024-001
    Material Weakness Repeat
  • 546928 2024-002
    Significant Deficiency Repeat
  • 546929 2024-002
    Significant Deficiency Repeat
  • 546930 2024-003
    Material Weakness Repeat
  • 546931 2024-003
    Material Weakness Repeat
  • 546932 2024-004
    Significant Deficiency
  • 546933 2024-004
    Significant Deficiency
  • 546934 2024-005
    Significant Deficiency Repeat
  • 546935 2024-005
    Significant Deficiency Repeat
  • 546936 2024-006
    Material Weakness Repeat
  • 546937 2024-006
    Material Weakness Repeat
  • 1123367 2024-001
    Material Weakness Repeat
  • 1123368 2024-001
    Material Weakness Repeat
  • 1123369 2024-001
    Material Weakness Repeat
  • 1123370 2024-002
    Significant Deficiency Repeat
  • 1123371 2024-002
    Significant Deficiency Repeat
  • 1123372 2024-003
    Material Weakness Repeat
  • 1123373 2024-003
    Material Weakness Repeat
  • 1123374 2024-004
    Significant Deficiency
  • 1123375 2024-004
    Significant Deficiency
  • 1123376 2024-005
    Significant Deficiency Repeat
  • 1123377 2024-005
    Significant Deficiency Repeat
  • 1123378 2024-006
    Material Weakness Repeat
  • 1123379 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $915,586
93.569 Community Services Block Grant $223,398
84.007 Federal Supplemental Educational Opportunity Grants $56,888
84.033 Federal Work-Study Program $8,996
84.268 Federal Direct Student Loans $6,112