Audit 332298

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

Criteria or Specific Requirements 34 CFR 668.22(f)(1)(i) For purpose of paragraph (e)(2)(i) of this section, the percentage of the payment period or period of enrollment completed is determined in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. 34 CFR 668.22(l)(9) A student in a program offered in modules is scheduled to complete the days in a module if the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, Higher Education Act funds for the payment period or period of enrollment. Condition Significant Deficiency in Internal Control over Compliance – We noted the following noncompliance for Return to Title IV calculations: 1. One out of sixty Return to Title IV (R2T4) calculations did not calculate the correct number of days completed based on the module courses the student withdrew from. 2. One out of sixty R2T4 calculations did not calculate the correct number of days in the period of enrollment related to the module course. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 661 calculations performed by the District during the 2024 fiscal year. Effect Without proper monitoring of calculations performed over students enrolled in module courses, the District is at risk of noncompliance with the above referenced criteria. Cause The District’s internal controls associated with the Return to Title IV procedures failed to ensure that all calculations are done accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the calculations are accurately calculated. View of Responsible Officials and Corrective Action Plan The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.