Finding Text
2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance
Department of Education
Student Financial Assistance Cluster
Department of Education
Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007
Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant
Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364
Award Year: 2022-23
Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – Undeterminable.
Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government.
Repeat finding – No
Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation.
Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.