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 2024-002
The twenty impacted students noted in Finding 2024-002 were tied to just two disbursement batches - dated September 28, 2023, and February 28, 2024 — not twenty separate events. In both cases, disbursements were accurately recorded in COD, funds were available to students on time, and G-5 draws were eventually completed (during year-end reconciliation) in September 2024. Since the majority of the funds in these disbursement batches were FSEOG, there was not a significant impact on ED Title IV accounting due to FSEOG budgets being predetermined and capped. Additionally, the amounts of these disbursements were credited to students’ accounts, so they were not disadvantaged by this administrative delay.
As with the instances in Finding 1 these delays resulted from administrative oversight and human error. While disbursements were initiated in Regent, the full-step process not properly completed, and the managing staff failed to conduct a timely review that would have identified that funds were requested but never received. These issues occurred during periods of major administrative transitions—first, during the initial implementation of Regent in the fall, and then in the spring, during the departure of the former Financial Aid Director and the handoff between third-party servicers. These were isolated incidents caused by temporary disruptions to our internal controls, not indicators of systemic risk. All underlying conditions have since been fully resolved.
In response, as outlined in our response to Finding 1, we conducted a full review and overhaul of our Title IV processes. As of Spring 2024, Financial Aid Solutions (FAS) has assumed direct management of awarding, disbursement, and cash management for the 2024–25 academic year. This support has enabled us to fully leverage Regent’s compliance features, enforce strict reconciliation protocols through FAS, and add real-time oversight by Hult’s central finance team.
Specifically, to ensure timely and accurate G-5 draws:
• FAS manages Title IV disbursements, including the G5 draw downs and reconciliations with COD
• All disbursement process steps are actioned within the same business day to reduce errors
• Hult has implemented internal controls to reconcile Title IV cash transactions against student ledgers within 1-2 business days
• Hult’s revised the monthly bank reconciliation of the federal account to specifically capture unfunded disbursements
These measures have established strong safeguards for the Title IV cash management operations. With these protocols in place, we are confident that delayed G-5 draws will not recur in the 2024-2025 award year or beyond.