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).
The Code of Federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the College, or any other third party.
Condition: During our testing of the 240-day requirement, we identified the College was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued.
Questioned costs:
$49,049.
Context: During our testing, we identified 27 out of 57 outstanding student checks were Title IV federal funds checks that were not returned within the 240-day limit.
Cause: The College did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year.
Effect: The College is not in compliance with Department of Education requirements.
Repeat finding: No
Recommendation: CLA recommends that the College review the requirements and implement a monitoring control to monitor and return the checks throughout the year.
Views of Responsible Officials: There is no disagreement with the audit finding.