Finding Text
Criteria or Specific Requirement:
Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
In accordance with 34 CFR 668.22(a)(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 grant or loan assistance that the student earned as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The determination of the difference is often referred to as Return of Title IV (R2T4) calculations.
Condition: There was one out of eighteen students tested where an input error in the Return of Title IV(R2T4) funds included in the calculation resulting in an error. In addition, there was not an observable internal control over the R2T4 process to prevent errors.
Questioned Costs:
84.063 – Federal Pell Grant Programs – $132
Context: The institution does not have internal controls in place to ensure compliance with the Return of Title IV compliance requirement. In addition, during the testing of R2T4 funds, we identified one out of eighteen students tested where the College’s manual calculation included an input error resulting in and underpayment of Title IV funds to the Department of Education.
Cause: There are no internal controls in place to prevent and detect errors in the R2T4 process in a timely manner.
Effect: Errors in the R2T4 process could go undetected or not be identified in a timely manner.
Repeat finding: No
Recommendation: The college should implement policies and procedures to ensure compliance with Return of Title IV compliance requirements.
Views of responsible officials: There is no disagreement with the audit finding.