2025-002 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Untimely Return of Title IV Refunds (Significant Deficiency) Condition: From a population of 40 students that unofficially withdrew during the academic year, we tested four students and noted that all four students ...
2025-002 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Untimely Return of Title IV Refunds (Significant Deficiency) Condition: From a population of 40 students that unofficially withdrew during the academic year, we tested four students and noted that all four students required refund calculations. R2T4 calculations were not prepared for three of the four students. Criteria: For a student who withdrawals, without providing notification, from a school that is not required to take attendance, the school must determine the withdrawal date no later than 30 days after the end of the earlier of (1) the payment period or the period of enrollment (as applicable), (2) the academic year, or (3) the student’s educational program. An institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew (34 CFR Section 668.22(a)(6)(j)(1)). Cause: Controls to ensure timely preparation of Title IV refunds did not function as related to the condition above. Effect: R2T4 calculations were not prepared for three students tested that unofficially withdrew resulting in untimely return of funds to the Department of Education. Repeat Finding from a Prior Year: No Recommendation: We recommend the University review and update its procedures to ensure timely preparation of Title IV refunds for students that unofficial withdrawal. View of Responsible Officials: Lander University acknowledges the finding related to the untimely return of Title IV funds and recognizes the seriousness of this compliance matter. The University has conducted a comprehensive review of its processes related to the identification of unofficial withdrawals and the timely completion of Return of Title IV (R2T4) calculations. The review determined that the prior process relied on a single point of control within the Financial Aid Office to identify unofficial withdrawals and initiate R2T4 calculations. During the period under review, that control did not function as intended, resulting in certain students not being identified in a timely manner and required R2T4 calculations not being completed within regulatory timeframes. In response, the University has redesigned the control environment governing unofficial withdrawal identification and R2T4 processing to introduce multiple, independent points of review and verification, and to formalize cross-office responsibilities. Under the revised process, faculty are required, pursuant to institutional grading policy, to document the student’s last date of academically related activity when assigning grades indicative of non-participation. At the conclusion of each academic term, the Registrar’s Office performs a structured review of students receiving grades associated with non-attendance to identify those who may have unofficially withdrawn from all coursework. The Registrar reviews the documented information for completeness and consistency and records the verified last date of attendance or participation in the student information system. The verified information is then provided to the Financial Aid Office, which completes the required R2T4 calculation within established timelines. The process now includes multiple levels of review, including supervisory and director-level oversight within Financial Aid, to ensure calculations are completed accurately and timely. Relevant information is also communicated to Student Accounts and the Registrar to ensure appropriate billing, notification, and enrollment reporting. These revised procedures have been implemented and are designed to eliminate reliance on a single control, strengthen accountability across offices, and ensure timely identification of unofficial withdrawals and prompt return of Title IV funds. Through these corrective actions, the University has strengthened its internal controls and is committed to maintaining full compliance with federal Title IV requirements. Joseph T. Greenthal Vice President for Finance and Administration Lander University