Finding 547609 (2024-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351778
Organization: Antioch University (OH)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The University failed to correctly calculate and timely return Title IV funds for some students, violating federal regulations.
  • Impacted Requirements: Noncompliance with 34 CFR 668.22 and FSA Handbook guidelines regarding the administration of federal student aid.
  • Recommended Follow-Up: Establish a quality assurance process with stronger controls to ensure compliance and prevent future errors.

Finding Text

Finding 2024-001 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2024 Criteria: 34 CFR 668.22 requires the University to implement internal control procedures and to appropriately administer funding under the Student Financial Assistance Cluster to return Title IV funds in the appropriate time required by regulations. Condition: During the course of our testing, we identified one student from a sample of nine whose Title IV refunds were not calculated correctly. Additionally, we identified one student from a sample of nine whose return of Title IV aid was not returned in the appropriate time required. Cause: Administrative oversight by personnel in calculating and reporting the status accurately and timely did not operate as designed Context: Controls did not operate properly to refund students with Federal Direct loans or Pell grants. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to return aid properly to the students. Questioned Costs: None Repeat Finding: Yes Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan on page 39-42.

Corrective Action Plan

1. Identifying Number: 2024-001: Title IV Refund and Return of Funds Compliance Issue: A sample review found instances where Title IV refunds were miscalculated and not returned within the required timeframe. Cause: Administrative oversight led to inaccurate and untimely calculation. Effect: The University did not fully comply with FSA Handbook and federal regulations for returning Title IV aid in a timely manner. Corrective Actions Underway 1. Enhanced Quality Assurance Measures Implementation of a new review protocol for Title IV refund calculations, including a secondary verification process before fund returns. Establishment of a biweekly internal audit of refund calculations to identify and resolve errors before submission. 2.Ongoing Compliance Monitoring and Prevention Efforts Establishment of a quarterly compliance review conducted by the Financial Aid leadership team to proactively address potential issues. Development of a standardized documentation process for all Title IV transactions and NSLDS updates to ensure clear audit trails. Creation of staff retraining initiative to reinforce compliance expectations and best practices. Next Steps: Conduct a full compliance assessment at 30, 60, and 90 days to confirm improvement and adjust protocols as needed. Establish a reporting dashboard for real-time tracking of Title IV refunds and enrollment status updates. Formalize a policy review cycle to ensure that all processes remain aligned with the latest federal regulations. These actions are intended to strengthen the University’s compliance posture, mitigate risks, and enhance the accuracy and timeliness of financial aid administration. Please let me know if additional measures or oversight mechanisms should be considered. Person Responsible for Corrective Action:The Executive Director of Financial Aid & Scholarships is responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2025

Categories

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

Other Findings in this Audit

  • 547610 2024-002
    Significant Deficiency Repeat
  • 547611 2024-001
    Significant Deficiency Repeat
  • 547612 2024-002
    Significant Deficiency Repeat
  • 1124051 2024-001
    Significant Deficiency Repeat
  • 1124052 2024-002
    Significant Deficiency Repeat
  • 1124053 2024-001
    Significant Deficiency Repeat
  • 1124054 2024-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $66.31M
84.033 Federal Work-Study Program $1.04M
84.063 Federal Pell Grant Program $650,309
93.191 Graduate Psychology Education $452,605
84.007 Federal Supplemental Educational Opportunity Grants $392,781
93.732 Mental and Behavioral Health Education and Training Grants $391,635
94.013 Americorps Volunteers in Service to America 94.013 $83,679
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $79,183
10.684 International Forestry Programs $43,030
45.313 Laura Bush 21st Century Librarian Program $39,283
66.950 National Environmental Education Training Program $34,981
11.431 Climate and Atmospheric Research $34,076
15.945 Cooperative Research and Training Programs – Resources of the National Park System $15,784
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772