Finding 1078012 (2024-001)

2024-001 Special Tests and Provisions: Return of Title IV Funds Student financial aid programs cluster Significant Deficiency in Internal Control 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 aid earned by the student as of the student's withdrawal date, and return any funds not earned by the student through attendance. Statement of Condition During our testing of the regulations, one student who was identified as a withdrawn student and did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. As a result of the audit inquiry, this calculation was performed and funds were returned, however the funds were returned outside of the required 45 day window. Additional analysis performed during testing confirmed that no additional students were overlooked as a result of this condition. Statement of Cause Due to recent staffing changes, the University did not have an adequate process in place for reviewing the students who are subject to a potential return of funds due to their withdrawal. As a result, the student was not properly identified and the calculation and subsequent return of funds was not performed in accordance with the University's policy or the CFR's guidelines. Possible Asserted Effect The University did not have adequate processes or controls in place to ensure compliance with the applicable regulations regarding Title IV funds. Recommendations The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Management's response See Corrective Action Plan.