Finding 620497 (2022-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-06-14
Audit: 47493
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The College failed to timely identify student withdrawals, leading to delays in the return of Title IV funds for seven out of 24 sampled cases.
  • Impacted Requirements: Compliance with 34 CFR Section 668.22 and 668.173(b) regarding timely calculations and remittances of Title IV funds.
  • Recommended Follow-Up: Implement a process for timely identification of withdrawals and ensure calculations are completed within the required 45-day timeframe.

Finding Text

FINDING 2022-002 ? 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 Numbers: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2021-22 Criteria: Per 34 CFR Section 668.22; When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. 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 Condition and context: A sample of 24 students who were recipients of Title IV funding and had withdrawn during the year was selected for our testing procedures.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 59 total withdrawals. Student records were compared to the calculation of the return of Title IV funds. We noted that the identification of withdrawn students is not timely, therefore, the initial calculation to return Title IV was late for seven of the twenty-four selected for testing with four as official withdrawals and three as unofficial withdrawals. Questioned costs: None Effect: The College did not perform the Title IV calculation within a reasonable time, and as such the return of funds was delayed. Cause: This occurred because the process in place was not designed effectively to identify the withdrawal of students, either official or unofficial, to calculate the return of Title IV funds and to remit amounts on a timely basis. Repeat finding: Yes, 2021-002 Recommendation: We recommend the College implement a process to identify official and unofficial withdrawals on a timely basis and that the calculations be performed within the required timeframe. Views of responsible officials and planned corrective actions: Official Withdrawals: Financial Aid Counselors are responsible for the Identification of Official Withdrawals through the Attendance Pattern Comparison Report (APCR), which is run every Monday (or next business day). Each Counselor (control #1) is responsible for the performance of the R2T4 form for their respective students and forward to the designated Counselor (control #2) to ensure accuracy and completion. Control #2 is responsible to manually input the calculations into Datatel and ensure adjustments, if any, are processed and returned via COD. This action is to be completed and included in the next scheduled batch closure or no later than 45 days from the date of withdrawal. Unofficial Withdrawals: After final grades have been posted at the end of each session or semester, each counselor will review their respective students through student transcript, identify those with ?zero credits earned? and determine last date of attendance. Official Withdrawal procedures will then be performed. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS by the Financial Aid Coordinator (with FA Officer as alternate) within 45 days. Anticipated completion of the corrective action is expected by June 2023.

Categories

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Reporting Significant Deficiency

Other Findings in this Audit

  • 44051 2022-005
    Significant Deficiency
  • 44052 2022-003
    Significant Deficiency Repeat
  • 44053 2022-004
    Significant Deficiency Repeat
  • 44054 2022-004
    Significant Deficiency Repeat
  • 44055 2022-002
    Significant Deficiency Repeat
  • 44056 2022-002
    Significant Deficiency Repeat
  • 44057 2022-002
    Significant Deficiency Repeat
  • 44058 2022-004
    Significant Deficiency Repeat
  • 620493 2022-005
    Significant Deficiency
  • 620494 2022-003
    Significant Deficiency Repeat
  • 620495 2022-004
    Significant Deficiency Repeat
  • 620496 2022-004
    Significant Deficiency Repeat
  • 620498 2022-002
    Significant Deficiency Repeat
  • 620499 2022-002
    Significant Deficiency Repeat
  • 620500 2022-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $4.73M
84.425 Education Stabilization Fund $3.29M
15.875 Economic, Social, and Political Development of the Territories $1.69M
10.511 Smith-Lever Funding (various Programs) $1.18M
10.203 Payments to Agricultural Experiment Stations Under the Hatch Act $907,355
10.664 Cooperative Forestry Assistance $384,851
84.027 Special Education_grants to States $311,332
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $268,951
93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service $255,407
84.002 Adult Education - Basic Grants to States $207,328
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $197,023
10.322 Distance Education Grants for Institutions of Higher Education in Insular Areas $151,022
59.037 Small Business Development Centers $139,003
84.007 Federal Supplemental Educational Opportunity Grants $134,519
47.076 Education and Human Resources $131,573
93.612 Native American Programs $114,417
10.308 Resident Instruction Grants for Insular Area Activities $78,908
10.514 Expanded Food and Nutrition Education Program $75,048
84.033 Federal Work-Study Program $48,965
93.310 Trans-Nih Research Support $33,769
15.945 Cooperative Research and Training Programs ? Resources of the National Park System $22,733
10.229 Extension Collaborative on Immunization Teaching & Engagement $21,335
93.569 Community Services Block Grant $16,452
15.630 Coastal Program $12,478
11.473 Office for Coastal Management $10,000
66.716 Research, Development, Monitoring, Public Education, Training, Demonstrations, and Studies $7,568
93.630 Developmental Disabilities Basic Support and Advocacy Grants $6,309
93.791 Money Follows the Person Rebalancing Demonstration $6,062