Finding #2: Untimely Return of Title IV Funds (R2T4)
Criteria:
Under 34 CFR 668.22(j), institutions must return unearned Title IV funds no later than 45
days from the date the institution determines that a student has withdrawn.
Condition:
Six R2T4s were submitted late. While four were linked to thi...
Finding #2: Untimely Return of Title IV Funds (R2T4)
Criteria:
Under 34 CFR 668.22(j), institutions must return unearned Title IV funds no later than 45
days from the date the institution determines that a student has withdrawn.
Condition:
Six R2T4s were submitted late. While four were linked to third-party service platform
transitions, two delays were related to students experiencing hardship (homelessness and
mental health emergencies) and internal documentation gaps.
Effect:
Noncompliance with R2T4 deadlines may result in program findings, increased liabilities,
and recurring audit scrutiny if unresolved.
Corrective Actions for R2T4:
6. R2T4 Tracker Implementation
o Action: Launch a live R2T4 tracker in Campus Café, flagged by withdrawal
status and showing days remaining until the 45-day deadline.
o Due Date: May 15, 2025
o Lead: Registrar, Business Office, Financial Aid Lead
7. Case Ownership Assignment Protocol
o Action: Assign R2T4 responsibility to ECM and Business Office, written
timelines and escalation criteria.
o Due Date: May 15, 2025
o Lead: Executive Director
8. R2T4 Checklist & Escalation Framework
o Action: Finalize a standardized checklist for all R2T4 cases including
withdrawal date, calculation verification, fund return confirmation, and dual
review.
o Due Date: May 15, 2025
o Lead: Operations Manager
9. Quarterly R2T4 Audit
o Action: Conduct quarterly compliance audits on all R2T4 files and include
findings in compliance reports.
o Due Date: First audit by June 30, 2025
o Lead: Compliance Officer
10. Emergency Circumstance Protocol
o Action: Document a formal protocol for handling R2T4 cases with student
hardship that allows internal escalation, verification, and documentation of
exception handling.
o Due Date: July 1, 2025
o Lead: Executive Director
Monitoring Plan:
Compliance will provide a quarterly report on R2T4 timeliness to the Executive Director.
Any case that nears 35 days will be auto escalated for executive intervention.