Finding Text
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Significant Deficiency in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR Section 668.22(e)(2): Percentage earned. The percentage of Title IV grant or loan
assistance that has been earned by the student is—
(i) Equal to the percentage of the payment period or period of enrollment that the student
completed (as determined in accordance with paragraph (f) of this section) as of the student’s
withdrawal date, if this date occurs on or before—
(A) Completion of 60 percent of the payment period or period of enrollment for a program that
is measured in credit hours; or
(B) 60 percent of the clock hours scheduled to be completed for the payment period or period
of enrollment for a program that is measured in clock hours; or
(ii) 100 percent, if the student’s withdrawal date occurs after—
(A) Completion of 60 percent of the payment period or period of enrollment for a program that
is measured in credit hours; or
(B) 60 percent of the clock hours scheduled to be completed for the payment period or period
of enrollment for a program measured in clock hours.
34 CFR Section 668.22(f)(2): The total number of calendar days in a payment period or period of
enrollment includes all days within the period that the student was scheduled to complete, except that
scheduled breaks of at least five consecutive days are excluded from the total number of calendar
days in a payment period or period of enrollment and the number of calendar days completed in that
period.
Condition/Context – A sample of 3 out of a population of 8 federal aid recipient students who
withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year were
selected. Student records were compared to the calculation of the return of Title IV funds, if any, and
the federal government’s Common Origin and Disbursement system. For one of the selected
students, the amount to be returned was calculated incorrectly. This resulted in an understatement of
student financial assistance earned by the student.
Questioned Costs – Known questioned costs were $38. We projected the error rate over the entire
universe of students who received federal aid and withdrew, dropped out, or enrolled but never
attended during the 2023-2024 school year. Using this method, we determined likely questioned
costs to be approximately $76. Effect – When the return of Title IV funds is not correctly calculated, the student ultimately receives
the incorrect amount of funding.
Cause – The College incorrectly calculated the length of a scheduled break in excess of five days
and the College incorrectly calculated the total number of days of class the student attended prior to
their withdrawal.
Repeat Finding – This is not a repeat finding.
Recommendation – We recommend the College implement a process by which all academic
calendars are thoroughly reviewed for scheduled breaks of at least five consecutive days to ensure
such breaks are accurately accounted for within the total number of calendar days in a payment
period or period of enrollment. Secondly, we recommend the College ensure recalculations of total
number of days attended and total number of days within the payment period or period of enrollment
are incorporated into its existing internal controls around the reviewer of Return of Title IV
calculations.
Views of responsible officials and planned corrective actions – The College acknowledges the
oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective
measures to ensure system accuracy. At least two financial aid officers will now verify semester
start/end dates and break periods, and the 60% mark will be calculated at the beginning of each
semester. Additionally, the COD R2T4 calculator will be used for comparison with internal
calculations. Withdrawal and R2T4 policies are also being updated for the 2024-25 College catalog.