Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Federal Supplemental Educational Opportunity Grants, Assistance Listing 84.007 Direct Loan Student Loans, Assistance Listing 84.268 Criteria: The College must comply wi...
Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Federal Supplemental Educational Opportunity Grants, Assistance Listing 84.007 Direct Loan Student Loans, Assistance Listing 84.268 Criteria: The College must comply with 34 CFR Section 668.22(a). Condition: We tested nine unofficial withdrawals, which included eight students enrolled in modules. For four of these students, the College used the number of days in the module the student withdrew from, instead of using the total amount days the student was enrolled in on the first day of the period or at any time during the period, based on the Title IV rules for modular enrollment. This resulted in the incorrect denominator and inaccurate calculations of earned and unearned aid. For one sample, the student earned sufficient credit hours in the first Fall module to be considered half-time. However the College still performed a return of funds calculation when the student withdrew from the second module even though no return of funds was required based on the Title IV rules for modular enrollment. Upon further analysis, there were 34 student that withdrew from the College during the year that were enrolled in modular programs and 12 of those students had an incorrect return of funds calculation. Cause: The College did not have adequate procedures to ensure that the return of funds calculations for modular students were performed in accordance with federal regulations. In addition, the College’s procedures did not include controls to identify circumstances in which return of funds were not required for modular students, such as when a student has already earned sufficient credit hours before withdrawal. Effect: Incorrect return of funds calculations for modular students led to inaccurate determinations of earned and unearned Title IV aid. Recommendation: We recommend the College implement controls to ensure the number of days used in the return of funds calculation is accurate based on the module-specific rules. We also recommend the College implement a review process to confirm whether a student has completed sufficient coursework to be considered half-time, thereby exempting them from the return of funds requirements, and to provide training to financial aid staff on the return of funds requirements from student enrolled in module programs. Views of responsible officials and planned corrective actions: The Director of Financial Aid will review the student’s enrollment on a module-by module basis at the time of withdrawal to determine the applicable payment period and correct number of days in the period. The Director of Financial Aid will develop a standardized R2T4 checklist for module programs that include identification of all modules within the payment period, confirmation of the student’s start and end dates for each module, and documentation of the total days in the payment period and days completed a the time of withdrawal. To ensure appropriate identification of students who may be exempt from R2T4 requirements due to completion of sufficient coursework, the Director of Financial Aid will establish a formal review process to include the following: 1) Prior to completing an R2T4 calculation, Director of Financial Aid will verify whether the student successfully completed coursework equal to or greater than half-time enrollment, in accordance with federal regulations. 2) This review will include confirmation of: a. Completed credit hours b. Applicable academic records or grades 3) Documentation of the half-time determination will be maintained in the student’s financial aid file to support exemption decisions when applicable The College will enhance training efforts to ensure staff are fully informed of R2T4 requirements specific to module-based enrollment. Training will be conducted annually and incorporated into onboarding for new staff. Completion date: 2/10/2026. Responsible staff: Crystal Benton, Director of Financial Aid.