2025-001 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Incorrect Return of Title IV (R2T4) Calculations (Significant Deficiency). Condition: From a population of 17 students that officially or unofficially withdrew during the term, we tested four students. All four stud...
2025-001 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Incorrect Return of Title IV (R2T4) Calculations (Significant Deficiency). Condition: From a population of 17 students that officially or unofficially withdrew during the term, we tested four students. All four students required Return of Title IV (R2T4) refund calculations. During our review, we noted that the University excluded only five days from the total number of days in the semester for the Fall 2024 and Spring 2025 breaks. However, each break period included five weekdays plus the surrounding weekend days, resulting in a total of nine days that should have been excluded. The University did not exclude the four weekend days adjacent to the breaks, leading to incorrect total day counts in the R2T4 calculations. Criteria: Under 34 CFR §668.22(f)(2)(i), the total number of calendar days in a payment period includes all days within the period that a student was scheduled to complete, except scheduled breaks of at least five consecutive days, which must be excluded from both the total number of days and the number of days completed. When classes end on a Friday and resume the following Monday after a week‑long break, both weekends (four days) and the five weekdays of the break are excluded from the R2T4 calculation, for a total exclusion of nine days. Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the condition above. Effect: R2T4 calculations for the students tested who withdrew during the Fall 2024 and Spring 2025 terms were incorrect. As a result, funds were returned in incorrect amounts to both the students and the U.S. Department of Education. Repeat Finding: No. Recommendation: We recommend the University implement and document enhanced procedures to ensure the accurate preparation and review of all Title IV refund calculations, including verification of the correct number of days excluded for scheduled breaks. View of Responsible Officials: The University acknowledges the condition identified. For the Fall 2024 and Spring 2025 terms, the R2T4 calculations excluded only the five instructional weekdays associated with each break and did not exclude the adjacent weekend days. As a result the total number of days in the payment period was overstated, which affected the R2T4 calculations for the students tested. Corrective Action: The University has reviewed the applicable regulatory requirements under 34 CFR§668.22(f)(2)(i) and confirmed that when a scheduled break consists of at least five consecutive days, all calendar days within the break period-including the surrounding weekends when classes end on a Friday and resume the following Monday-must be excluded from the R2T4 calculation. The University has: 1) Recalculated the affected R2T4 determinations for the students identified to ensure the correct number of days is excluded, 2) Returned or recovered any resulting differences in funds, as required, to or from the U.S. Department of Education and the affected students, 3) Updated internal R2T4 calculation procedures and reference materials to explicitly require exclusion of both weekdays and associated weekend days for qualifying scheduled breaks, and 4) Provided additional training to staff responsible for R2T4 calculations to reinforce regulatory requirements and prevent recurrence. Status: Corrective actions have been applied, and revised controls implemented for all future R2T4 calculations to ensure compliance with federal regulations. If the Federal Audit Clearinghouse has questions regarding this plan, please call Amy Brown, Director of Financial Aid at 704-463-3015.