Finding Text
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.