Finding Text
FINDING 2022-003?Special Tests and Provisions?Disbursements: Significant Deficiency in Internal Control Over Compliance "See Schedule of Findings and Questioned Costs for chart/table." Criteria ? 34 CFR 668.164 Disbursing funds ? (h) Title IV, HEA credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student?s ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period as provided under paragraph (c) of this section. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition/context ? A sample of 10 students was selected from the population of all students disbursed federal student financial aid by the University during the year ended June 30, 2022. We obtained the students records and tested the student?s compliance with federal regulations for the specific loans and grants for which each individual student was disbursed. For one undergraduate student selected, federal student aid was disbursed, creating a credit balance which was not refunded to the student within the 14-day requirement. Cause ? Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility were unable to perform the task according to the required timeframes. Effect ? The University was not in compliance with disbursement requirements. Repeat finding ? This is a repeat finding. See 2021-003. Recommendation ? We recommend the University revise its policies to establish cross-training protocols for responsibilities related to disbursement of federal aid. View of responsible officials ? Management acknowledges the deficiency. Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables us to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations.