Corrective Actions: To strengthen internal controls and ensure full compliance with federal regulations, the University has implemented the following measures: 1. Secondary Review Implementation: The University has contracted with an external consultant to serve as a secondary reviewer. In the inter...
Corrective Actions: To strengthen internal controls and ensure full compliance with federal regulations, the University has implemented the following measures: 1. Secondary Review Implementation: The University has contracted with an external consultant to serve as a secondary reviewer. In the interim, an internal staff member is receiving comprehensive R2T4 training and will complete the NASFAA Return of Title IV Funds Certification Program in March 2026. Upon completion of the NASFAA Program coursework, the staff member will complete an examination on or before May 31, 2026. Once certification is achieved and the University has full confidence in the internal review process, the secondary review function will transition from the external consultant to an in-house process. 2. Documentation Retention Enhancement: The University has reinforced procedures, including those document retention protocols, by adding this as an additional checklist item on the R2T4 checklist, to ensure that all post-withdrawal disbursement notifications are properly retained in each student’s financial aid record, either electronically or within the designated document management system. The checklist is meant to be a roadmap for the reviewer to ensure each step is completed in the calculation process and that documentation is retained for post-withdrawal disbursement. 3. Staff Training: All financial aid staff involved in the R2T4 process have received updated training on the correct handling of loan returns and post-withdrawal notifications in accordance with 34 CFR 668.22 and current FSA Handbook guidance. Staff involved with R2T4 administration include the Financial Aid Business Analyst and a Financial Aid Advisor. Both team members have completed either official NASFAA or FSA training. The Financial Aid Advisor will be completing the NASFAA Certificate training on R2T4. Additionally, the Assistant Director will also complete the program at the same time, increasing the depth of knowledge for the team around this topic. Responsible Official: Doug Cleary, Director of Financial Aid Estimated Completion Date: May 31, 2026