Finding 7932 (2023-001)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-01-09
Audit: 10341
Organization: Cuyahoga Community College (OH)

AI Summary

  • Core Issue: The College failed to return Title IV funds to the Department of Education within the required 45-day period for some withdrawn students.
  • Impacted Requirements: Compliance with federal regulations (34 CFR 668.173(b)) regarding timely returns of Title IV funds.
  • Recommended Follow-Up: Implement a reliable process to ensure all Title IV aid returns are calculated and submitted on time.

Finding Text

Material Weakness and Material Noncompliance – Return of Title IV Funds Federal Program Information: Federal Pell Grant Program, ALN 84.063, Federal Supplemental Education Opportunity Grants, ALN 84.007, Federal Direct Student Loans, ALN 84.268 Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA 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 (34 CFR 668.173(b)). Condition: The College did not return Title IV funds to the ED within the required time frame for certain students who required a return of funds. Context: Of the 29 withdrawn students tested for proper return of Title IV funds, the funds for 6 students requiring a return were not returned to ED by the College within the required time frame. Questioned Costs: None Cause and Effect: A manual process the College had in place to identify students with return to Title IV calculations was not properly followed to make sure calculations performed were processed and returned to ED within the required time frame. This led to returns of Title IV funds to ED being completed after the required time frame. Recommendation: We recommend that the College institute a process to ensure that all returns of Title IV aid are calculated and returned within the required time frame. Management’s Response: See corrective action plan.

Corrective Action Plan

College Response: In November 2023, in conjunction with the College’s annual external audit, errors were identified in Cuyahoga Community College’s timely Return to Title IV funds. After careful internal review of the student records, all applicable corrections to student records were made to ensure compliance with federal regulations. All financial aid funds related to Return of Title IV funds had been returned to the U.S. Department of Education. In December 2023, the college completed a review of internal procedures and processes to mitigate untimely Return of Title IV funds in the future. Mitigation Strategy: The following process and procedural changes for the review of the Return of Title IV funds have been put in place to resolve the issue of late returns of funds as identified in the 2022-2023 external audit: 1. Retrained staff responsible for the Return of Title IV processing, including updates and revisions to the policies and procedure manual for this financial aid function to strengthen the internal quality check for manual review of the accuracy of returns 2. Identified and cross-train additional financial aid employees to support the high-volume financial aid process, including two team members to check and validate the timely processing and accuracy of the return of funds 3. Developed an enhanced report to compare completed calculations of the return of funds in Banner to the processed with the COD-generated report to verify the timely return of funds 4. Automated reports for Return of Title IV report to be delivered bi-weekly to the central mailbox, which will enable multiple employees to have access to the Return of Title IV reports and ensure more than one trained team member to timely process the return of funds to meet the 45-day federal requirement 5. Conduct a quality check of the Return of Title IV funds to assess the accuracy of the calculation and timely return of funds by conducting an internal Financial Aid Team review of 5-10% of the return of funds assessment every 60 days Anticipated Completion Date: 12/19/2023 Responsible Contact Person: Angela Johnson –VP of Enrollment Management

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness

Other Findings in this Audit

  • 7933 2023-001
    Material Weakness
  • 7934 2023-001
    Material Weakness
  • 7935 2023-001
    Material Weakness
  • 584374 2023-001
    Material Weakness
  • 584375 2023-001
    Material Weakness
  • 584376 2023-001
    Material Weakness
  • 584377 2023-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $21.49M
84.268 Federal Direct Student Loans $8.47M
84.002 Adult Education - Basic Grants to States $1.71M
17.259 Wioa Youth Activities $1.29M
84.007 Federal Supplemental Educational Opportunity Grants $1.09M
84.042 Trio_student Support Services $862,731
84.047 Trio_upward Bound $729,581
84.044 Trio_talent Search $677,553
84.048 Career and Technical Education -- Basic Grants to States $571,026
84.066 Trio_educational Opportunity Centers $406,565
93.859 Biomedical Research and Research Training $345,492
84.031 Higher Education_institutional Aid $342,878
93.516 Affordable Care Act (aca) Public Health Training Centers Program $196,308
84.033 Federal Work-Study Program $156,704
12.300 Basic and Applied Scientific Research $124,661
93.566 Refugee and Entrant Assistance_state Administered Programs $66,841
47.076 Education and Human Resources $35,361
84.425 Education Stabilization Fund $27,887
84.116 Fund for the Improvement of Postsecondary Education $24,406
45.024 Promotion of the Arts_grants to Organizations and Individuals $15,000
45.025 Promotion of the Arts_partnership Agreements $6,500
17.285 Apprenticeship USA Grants $5,412
17.268 H-1b Job Training Grants $4,350
12.006 National Defense Education Program $485