FAC Explorer

Finding 947124 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2024-02-27
Audit: 292382
Organization: Central Michigan University (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The University has a material weakness in handling Title IV fund returns, leading to discrepancies in calculations for students who withdrew.
  • Impacted Requirements: Federal regulations require accurate withdrawal dates and timely return of unearned funds, which were not consistently followed.
  • Recommended Follow-Up: Implement training and controls for staff, conduct regular audits, and ensure monthly reconciliations between enrollment and financial aid systems.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). 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 aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Categories

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

Other Findings in this Audit

  • 370657 2023-001
    Material Weakness Repeat
  • 370658 2023-002
    Material Weakness Repeat
  • 370659 2023-003
    Significant Deficiency
  • 370660 2023-004
    Significant Deficiency
  • 370661 2023-001
    Material Weakness Repeat
  • 370662 2023-002
    Material Weakness Repeat
  • 370663 2023-003
    Significant Deficiency
  • 370664 2023-004
    Significant Deficiency
  • 370665 2023-001
    Material Weakness Repeat
  • 370666 2023-002
    Material Weakness Repeat
  • 370667 2023-003
    Significant Deficiency
  • 370668 2023-004
    Significant Deficiency
  • 370669 2023-001
    Material Weakness Repeat
  • 370670 2023-002
    Material Weakness Repeat
  • 370671 2023-003
    Significant Deficiency
  • 370672 2023-004
    Significant Deficiency
  • 370673 2023-001
    Material Weakness Repeat
  • 370674 2023-002
    Material Weakness Repeat
  • 370675 2023-003
    Significant Deficiency
  • 370676 2023-004
    Significant Deficiency
  • 370677 2023-001
    Material Weakness Repeat
  • 370678 2023-002
    Material Weakness Repeat
  • 370679 2023-003
    Significant Deficiency
  • 370680 2023-004
    Significant Deficiency
  • 370681 2023-001
    Material Weakness Repeat
  • 370682 2023-002
    Material Weakness Repeat
  • 370683 2023-003
    Significant Deficiency
  • 370684 2023-004
    Significant Deficiency
  • 370685 2023-001
    Material Weakness Repeat
  • 370686 2023-002
    Material Weakness Repeat
  • 370687 2023-003
    Significant Deficiency
  • 370688 2023-004
    Significant Deficiency
  • 370689 2023-001
    Material Weakness Repeat
  • 370690 2023-002
    Material Weakness Repeat
  • 370691 2023-003
    Significant Deficiency
  • 370692 2023-004
    Significant Deficiency
  • 947099 2023-001
    Material Weakness Repeat
  • 947100 2023-002
    Material Weakness Repeat
  • 947101 2023-003
    Significant Deficiency
  • 947102 2023-004
    Significant Deficiency
  • 947103 2023-001
    Material Weakness Repeat
  • 947104 2023-002
    Material Weakness Repeat
  • 947105 2023-003
    Significant Deficiency
  • 947106 2023-004
    Significant Deficiency
  • 947107 2023-001
    Material Weakness Repeat
  • 947108 2023-002
    Material Weakness Repeat
  • 947109 2023-003
    Significant Deficiency
  • 947110 2023-004
    Significant Deficiency
  • 947111 2023-001
    Material Weakness Repeat
  • 947112 2023-002
    Material Weakness Repeat
  • 947113 2023-003
    Significant Deficiency
  • 947114 2023-004
    Significant Deficiency
  • 947115 2023-001
    Material Weakness Repeat
  • 947116 2023-002
    Material Weakness Repeat
  • 947117 2023-003
    Significant Deficiency
  • 947118 2023-004
    Significant Deficiency
  • 947119 2023-001
    Material Weakness Repeat
  • 947120 2023-002
    Material Weakness Repeat
  • 947121 2023-003
    Significant Deficiency
  • 947122 2023-004
    Significant Deficiency
  • 947123 2023-001
    Material Weakness Repeat
  • 947125 2023-003
    Significant Deficiency
  • 947126 2023-004
    Significant Deficiency
  • 947127 2023-001
    Material Weakness Repeat
  • 947128 2023-002
    Material Weakness Repeat
  • 947129 2023-003
    Significant Deficiency
  • 947130 2023-004
    Significant Deficiency
  • 947131 2023-001
    Material Weakness Repeat
  • 947132 2023-002
    Material Weakness Repeat
  • 947133 2023-003
    Significant Deficiency
  • 947134 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $27.96M
84.063 Federal Pell Grant Program $15.78M
84.033 Federal Work-Study Program $975,276
84.007 Federal Supplemental Educational Opportunity Grants $470,493
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $470,480
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $339,406
84.326 Special Education_technical Assistance and Dissemination to Improve Services and Results for Children with Disabilities $200,385
47.074 Biological Sciences $198,348
84.217 Trio_mcnair Post-Baccalaureate Achievement $195,671
84.044 Trio_talent Search $175,601
47.041 Engineering $171,750
12.910 Research and Technology Development $149,218
84.047 Trio_upward Bound $137,415
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $135,284
93.310 Trans-Nih Research Support $112,859
93.866 Aging Research $91,797
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $82,118
93.575 Child Care and Development Block Grant $78,800
11.300 Investments for Public Works and Economic Development Facilities $69,375
12.RD Benchmarking Quantum Enhancement in Science & Technology $68,262
93.211 Telehealth Programs $67,387
47.075 Social, Behavioral, and Economic Sciences $61,571
93.855 Allergy, Immunology and Transplantation Research $55,721
93.493 Cmu Telehealth Services & Information Technology $46,280
15.608 Fish and Wildlife Management Assistance $46,178
93.136 Injury Prevention and Control Research and State and Community Based Programs $45,888
11.417 Sea Grant Support $42,600
47.078 Polar Programs $41,719
93.395 Cancer Treatment Research $40,425
43.001 Science $39,698
93.110 Maternal and Child Health Federal Consolidated Programs $29,643
93.732 Mental and Behavioral Health Education and Training Grants $25,000
11.609 Measurement and Engineering Research and Standards $23,069
66.708 Pollution Prevention Grants Program $23,007
10.558 Child and Adult Care Food Program $22,617
12.006 National Defense Education Program $21,727
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $19,994
93.778 Medical Assistance Program $19,714
11.459 Weather and Air Quality Research $18,709
66.469 Great Lakes Program $18,657
93.838 Lung Diseases Research $17,661
81.049 Office of Science Financial Assistance Program $17,311
93.837 Cardiovascular Diseases Research $16,717
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $16,576
15.933 Preservation of Japanese American Confinement Sites $16,122
93.859 Biomedical Research and Research Training $15,756
12.630 Basic, Applied, and Advanced Research in Science and Engineering $15,696
66.461 Regional Wetland Program Development Grants $14,761
47.079 Office of International Science and Engineering $14,370
45.310 Grants to States $13,769
15.662 Great Lakes Restoration $13,335
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $11,099
89.003 National Historical Publications and Records Grants $10,742
12.420 Military Medical Research and Development $10,118
11.467 Meteorologic and Hydrologic Modernization Development $9,938
66.951 Environmental Education Grants $9,609
93.997 Assisted Outpatient Treatment $9,581
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $9,410
47.050 Geosciences $7,923
93.173 Research Related to Deafness and Communication Disorders $7,898
15.945 Cooperative Research and Training Programs Ð Resources of the National Park System $7,573
11.432 National Oceanic and Atmospheric Administration (noaa) Cooperative Institutes $5,955
84.181 Special Education-Grants for Infants and Families $5,863
84.305 Education Research, Development and Dissemination $4,359
93.865 Child Health and Human Development Extramural Research $3,681
93.399 Cancer Control $2,500
47.076 Education and Human Resources $2,200
16.607 Bulletproof Vest Partnership Program $1,368
47.049 Mathematical and Physical Sciences $120