General Background
During the 2023-2024 award year, Hult International Business School, Inc.’s (“Hult”) financial aid department faced a convergence of challenges that led to the findings noted in this audit. These included the transition to the Regent Education system, unexpected staff turnover - including the departure of the Director and subsequently, remaining team - complications stemming from the Department of Education’s FAFSA simplification rollout, and a transition to a new third-party servicer. While these disruptions created a challenging environment in AY23–24, they do not reflect Hult’s current or ongoing ability to effectively manage Title IV funds. Each of the former mitigating issues have since been addressed and resolved, and Hult took steps to significantly limit how students were impacted during this transitional period. Following the departure of key personnel in Spring 2024, we identified gaps in oversight and internal controls that warranted further attention. In response, we immediately removed the individual who had been responsible for oversight of the Financial Aid team and launched a cross-functional committee to conduct an internal audit and process overhaul. Our goal was not only to correct past mistakes but to build a stronger, more resilient foundation moving forward.
Key corrective actions include:
• Contracting Financial Aid Solutions (FAS) to manage core Title IV functions, including awarding, disbursement, and cash management activities for immediate compliance support, while we rebuilt our internal capacity
• Conducting a full review and overhaul of our processes, procedures, and Regent system configuration to align with business needs and Title IV compliance
• Hiring and training a qualified, in-house financial aid team, with a focus on cross-training and succession planning, to ensure continuity and operational stability
• Revising our existing internal controls managed by the financial aid team, and implementing new internal controls, independently managed by our central finance team, to ensure data accuracy, monitor for discrepancies, and enable prompt resolution of any identified issues
• Committing dedicated project management resources to identify process gaps, streamline operations, and optimize our use of system tools
These measures represent a deep and sustained investment in the integrity, compliance, and effectiveness of our Title IV operations. We take full responsibility for the instances raised and addressed in this report and are fully committed to preventing their recurrence. With these systems now in place, we are confident in our ability to maintain high-quality, compliant financial aid administration moving forward.
Corrective Action Plan - Finding 2024-001
Hult acknowledges that Title IV funds were returned outside the 45-day window in three instances, two of which were identified during the course of this audit preparation. These delays, caused by human errors from former staff who failed to follow timely reconciliation procedures and follow through on system-initiated returns, have since been corrected and all ineligible funds have been returned in full.
At this time, Hult was transitioning to a new Regent Education platform under two successive, financial aid directors. The second, despite claiming expertise with Regent, lacked the operational understanding needed for effective implementation and ongoing oversight of this system. While the individuals responsible for these occurrences are no longer with Hult, we accept full accountability for the errors and are committed to ensuring consistent, Title IV compliance moving forward.
Following the departure of our most recent director in late Spring 2024, we undertook a thorough review of our financial aid operations. This assessment identified key areas for administrative improvement, which we addressed immediately by engaging Financial Aid Solutions (FAS) to reinforce our compliance functions and provide us with interim, expert support.
Throughout Summer 2024, Hult implemented a comprehensive set of corrective actions to strengthen our internal controls and safeguard against future errors. These include:
• Extensively redeveloped and tested our Regent infrastructure – in close collaboration with Regent and FAS – to ensure the system operates effectively with Hult’s academic structure, ensures the accuracy of data outputs, and maintains compliance with Title IV regulations
• Hired a qualified, experienced, in-house financial aid team of three. We have and continue to prioritize cross-training and succession planning to ensure operational continuity
• Implemented a dual-review process for all Title IV awards, with FAS processing calculations in Regent and Hult staff independently verifying them before disbursing funds
• Introduced independent, recurring reconciliations of Title IV transactions by Hult’s central finance team, to ensure record accuracy and promptly resolve any issues identified
These ongoing efforts have established a more resilient and accountable operational framework. We are confident that with these controls in place, Hult will remain fully compliant with Title IV regulations, and there will be no repeat instances of late returns in the 2024–25 award year.