Audit 15219

Treatment of Title IV Funds when a Student Withdraws (Significant Deficiency) Department of Education, SFA Cluster Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic funds transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR 668.173(b). Condition: Eleven of the seventeen students selected for withdraw testing for the 2022-2023 academic year required a return of funds to the Department of Education. Return of Title IV funds occurred untimely for two students, exceeding 45 days as required, when considering the University’s date of determination as reported on R2T4 forms. Cause: The University does not have adequate procedures in place to ensure students’ Title IV funds are returned timely. R2T4 forms improperly reported the date of determination the same as the student withdraw date. Effect: The University failed to return Title IV funds to the Department of Education within 45 days of the students’ date of determination as reported on the R2T4 forms. Recommendation: We recommend that the University put procedures in place to ensure that R2T4 forms are filed timely and properly reflect the University’s date of determination for all student withdrawals. Management Response: Management determined the root cause of errors in the date of determination that the student withdrew (determination date), which ultimately led to funds not being returned within 45 days, was due to a process error. The old process relied on the Registrar’s Office to provide the actual date to use (through a Withdrawal Report). It was discovered that with only one date able to be captured in the current (antiquated) ERP that the Date of Withdrawal was the only date provided. In the short term, this is being resolved by the Registrar’s Office directly notifying the Financial Aid Office with both dates (not relying on a withdrawal report): Date of Withdrawal and Date of School’s Determination. Beginning 2024‑5 a new ERP will be in place that will allow both dates to show in the Financial Aid R2T4 module immediately as reported from the Registrar’s Office.

Update of Enrollment Status when a Student Withdraws (Significant Deficiency) Department of Education, SFA Cluster Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. Condition: Eleven of the seventeen students selected for withdraw testing for the 2022-2023 academic year required an update to NSLDS enrollment status. The enrollment status for one student was not updated after the student was no longer enrolled on at least a half-time basis. Cause: The University does not have adequate procedures in place to ensure students’ enrollment statuses are updated. Effect: The University failed update the NSLDS enrollment status. Recommendation: We recommend that the University put procedures in place to ensure that student enrollment statuses are updated following any change in full time enrollment status. Management Response: To ensure that student enrollment statuses are updated following any change in full time enrollment status, the University of Lynchburg is implementing a new Student information system (Ellucian Colleague) that will automate the management of student statuses based on NSLDS parameters and guidelines. The new system will drastically reduce the previous needs for the manual monitoring of student statuses. This new system will be fully implemented by August 2024. In the interim, the Registrar’s Office is stepping up its efforts to ensure that the current manual monitoring process is effective.

Treatment of Title IV Funds when a Student Withdraws (Significant Deficiency) Department of Education, SFA Cluster Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic funds transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR 668.173(b). Condition: Eleven of the seventeen students selected for withdraw testing for the 2022-2023 academic year required a return of funds to the Department of Education. Return of Title IV funds occurred untimely for two students, exceeding 45 days as required, when considering the University’s date of determination as reported on R2T4 forms. Cause: The University does not have adequate procedures in place to ensure students’ Title IV funds are returned timely. R2T4 forms improperly reported the date of determination the same as the student withdraw date. Effect: The University failed to return Title IV funds to the Department of Education within 45 days of the students’ date of determination as reported on the R2T4 forms. Recommendation: We recommend that the University put procedures in place to ensure that R2T4 forms are filed timely and properly reflect the University’s date of determination for all student withdrawals. Management Response: Management determined the root cause of errors in the date of determination that the student withdrew (determination date), which ultimately led to funds not being returned within 45 days, was due to a process error. The old process relied on the Registrar’s Office to provide the actual date to use (through a Withdrawal Report). It was discovered that with only one date able to be captured in the current (antiquated) ERP that the Date of Withdrawal was the only date provided. In the short term, this is being resolved by the Registrar’s Office directly notifying the Financial Aid Office with both dates (not relying on a withdrawal report): Date of Withdrawal and Date of School’s Determination. Beginning 2024‑5 a new ERP will be in place that will allow both dates to show in the Financial Aid R2T4 module immediately as reported from the Registrar’s Office.

Update of Enrollment Status when a Student Withdraws (Significant Deficiency) Department of Education, SFA Cluster Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. Condition: Eleven of the seventeen students selected for withdraw testing for the 2022-2023 academic year required an update to NSLDS enrollment status. The enrollment status for one student was not updated after the student was no longer enrolled on at least a half-time basis. Cause: The University does not have adequate procedures in place to ensure students’ enrollment statuses are updated. Effect: The University failed update the NSLDS enrollment status. Recommendation: We recommend that the University put procedures in place to ensure that student enrollment statuses are updated following any change in full time enrollment status. Management Response: To ensure that student enrollment statuses are updated following any change in full time enrollment status, the University of Lynchburg is implementing a new Student information system (Ellucian Colleague) that will automate the management of student statuses based on NSLDS parameters and guidelines. The new system will drastically reduce the previous needs for the manual monitoring of student statuses. This new system will be fully implemented by August 2024. In the interim, the Registrar’s Office is stepping up its efforts to ensure that the current manual monitoring process is effective.