Finding 2025-002 – Special Tests and Provisions – Return of Title IV Funds Contact Person: Cristen Alicea, Office of Financial Assistance Current status: In-Progress Anticipated Completion Date: May 1, 2026 Condition: The University did not provide evidence of an effective review process to ensure t...
Finding 2025-002 – Special Tests and Provisions – Return of Title IV Funds Contact Person: Cristen Alicea, Office of Financial Assistance Current status: In-Progress Anticipated Completion Date: May 1, 2026 Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not accurately calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Identification of repeat finding: Yes – 2024-002, 2023-002 Resolution: The Director of Financial Assistance performed a full review of all withdrawals during 2023-2024, and 2024-2025, to ensure calculations were complete, accurate, and funds returned as required. Documentation will be maintained for review by the auditors and the Department of Education to prove funds were returned correctly, even if not timely. The continuation of this issue was caused by the continued difficulty with recruiting and keeping financial assistance advisors, and the extraordinary disruption caused by the 2024-2025 FAFSA changes. We were unable to fully remediate our staffing issues during the 2024-2025 academic year. We brought on new staff which required extensive training. However, we are now able to spend more time focusing on compliance areas and will be able to fully implement our planned compliance controls during the 2025-2026 aid year. We will not have any returns unprocessed or made outside of 45 days after May 1, 2026. In addition to new staff and training, we will implement a secondary review process for all Return of Title IV transactions whereby an advisor will process the initial calculation and return, and then either the Assistant Director or Director of Financial Assistance will perform a secondary review which evaluates the date of the withdrawal, the date of determination, the eligible disbursed/non-disbursed aid amounts, the returned amounts, and confirms the returned amounts in Banner and COD. This internal review process will be performed upon 100% of Return of Title IV calculations each academic year.