Finding 559037 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-05-01
Audit: 355302
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The College incorrectly calculated the Return of Title IV funds, leading to an over-return of funds for students who withdrew during scheduled breaks.
  • Impacted Requirements: Compliance with 34 CFR Section 668.22 and the Federal Student Aid Handbook regarding the exclusion of scheduled breaks from R2T4 calculations was not followed.
  • Recommended Follow-Up: Ensure adherence to College policy by excluding breaks of five or more consecutive days in future R2T4 calculations to prevent funding discrepancies.

Finding Text

FINDING 2024-002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063, 84.007, 84.033 Federal Program Name: Federal Pell Grant Program Award Year: 2023-24 Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of their current academic period and is determined as having not earned 100 percent of their received Title IV assistance, an institution must return the total amount of unearned Title IV assistance received from withdrawn students. Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition and Context: A sample of 8 students who were recipients of Title IV funding and had withdrawn during the year was selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 42 total withdrawals consisting of 31 unofficial withdrawals and 8 official withdrawals. 4 of the students selected withdrew during the spring term, which included the spring break within the total days used in the R2T4 calculation. Based on the 2023-2024 Federal Student Aid Handbook, scheduled breaks lasting five or more consecutive days are excluded from the total and completed days in the R2T4 calculation (Volume 5, Chapter 1). Furthermore, 34 CFR 668.22 of the eCFR supports this rule by excluding such breaks from the calculation of the payment period. The College did not perform the Title IV calculation within the College’s policy or within Federal requirements, and therefore returned too much funding. Questioned costs: None. Effect: Of the 42 total withdraws, 20 occurred during the spring term resulting in the over return of funds. For the 4 students we tested, there was no impact to the student, but instead the College received less funding due to the over return. Cause: The College’s policy was not adhered to and as such was the control was not operating as intended. Repeat finding: No. Recommendation: We recommend the College ensure the policy is being followed which requires scheduled breaks lasting five or more consecutive days be excluded from the total and completed days in the R2T4 calculation. Views of responsible officials and planned corrective actions: Contact Person(s): Shanell Tauiliili, Financial Aid Officer Dr. Emilia Le' i, Dean of Student Services Letupu Moananu, Vice President of Academics, Community, and Student Affairs

Categories

Student Financial Aid Significant Deficiency Special Tests & Provisions Internal Control / Segregation of Duties

Other Findings in this Audit

  • 559035 2024-002
    Significant Deficiency
  • 559036 2024-002
    Significant Deficiency
  • 559038 2024-003
    Significant Deficiency Repeat
  • 1135477 2024-002
    Significant Deficiency
  • 1135478 2024-002
    Significant Deficiency
  • 1135479 2024-002
    Significant Deficiency
  • 1135480 2024-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $4.14M
84.425 Education Stabilization Fund $2.20M
10.511 Smith-Lever Extension Funding $2.00M
10.203 Payments to Agricultural Experiment Stations Under the Hatch Act $1.20M
11.028 Connecting Minority Communities Pilot Program $939,481
93.791 Money Follows the Person Rebalancing Demonstration $762,190
93.612 Native American Programs $400,728
84.027 Special Education Grants to States $298,972
84.002 Adult Education - Basic Grants to States $273,726
93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service $203,922
10.308 Resident Instruction, Agriculture, and Food Science Facilities and Equipment Grants $190,374
84.031 Higher Education Institutional Aid $184,770
93.107 Area Health Education Centers $183,785
10.766 Community Facilities Loans and Grants $153,074
10.514 Expanded Food and Nutrition Education Program $107,515
10.664 Cooperative Forestry Assistance $100,109
84.033 Federal Work-Study Program $88,128
10.322 Distance Education Grants for Institutions of Higher Education in Insular Areas $83,826
84.007 Federal Supplemental Educational Opportunity Grants $59,200
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $36,107
15.945 Cooperative Research and Training Programs � Resources of the National Park System $24,816
93.310 Trans-Nih Research Support $24,416
47.076 Stem Education (formerly Education and Human Resources) $21,963
15.630 Coastal $15,269
66.716 Research, Development, Monitoring, Public Education, Outreach, Training, Demonstrations, and Studies $10,708
93.569 Community Services Block Grant $7,670
15.875 Economic, Social, and Political Development of the Territories $4,703
10.229 Extension Collaborative on Immunization Teaching & Engagement $1,043
11.473 Office for Coastal Management $259