Finding Text
Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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: The college did not have a formal review process, as the student financial aid director was
both preparing and reviewing the calculation.
Context: Out of the forty sampled calculations, all forty lacked evidence of a formal review.
Questioned Costs: N/A
Cause: Lack of formal review of last date of attendance for online students including Canvas activity
logs.
Effect: No formal review could allow errors in the calculation and errors in the timing of payments.
Repeat Finding: No
Recommendation: We recommend someone other than the preparer of Return of Title IV calculations
review said calculations.
Views of Responsible Officials: Management agrees with the finding and has developed a plan to
correct the finding.