Finding 1084676 (2024-005)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-11-18

AI Summary

  • Core Issue: The University incorrectly returned Title IV funds in the wrong order during student withdrawals, violating federal regulations.
  • Impacted Requirements: Funds must be returned following a specific sequence: Unsubsidized loans first, then Subsidized loans, followed by grants.
  • Recommended Follow-Up: Ensure compliance by adhering to the correct return sequence and utilizing updated training and systems for future calculations.

Finding Text

2024-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Criteria: In accordance with 34 CFR 668.22(i), unearned funds returned by the institution or the student, as appropriate, must be credited to outstanding balances on Title IV loans made to the student or on behalf of the student for the payment period or period of enrollment for which a return of funds is required. Those funds must be credited to outstanding balances for the payment period or period of enrollment for which a return of funds is required in the following order: (i) Unsubsidized Federal Direct Stafford loans, (ii) Subsidized Federal Direct Stafford loans, (iii) Federal Direct PLUS received on behalf of the student. If unearned funds remain to be returned after repayment of all outstanding loan amounts, the remaining excess must be credited to any amount awarded for the payment period or period of enrollment for which a return of funds is required in the following order: (i) Federal Pell Grants, (ii) Iraq and Afghanistan Service Grants, (iii) FSEOG Program aid, (iv) TEACH Grants. Statement of Condition: During the audit, it was noted that the University returned funds in an incorrect sequence during the Return to Title IV Funds process upon student withdrawal. Questioned Costs: There is no known monetary error as the mistake causes a misclassification in type of award, but net award amount is not affected. Perspective Information: The audit included a detailed testing of 2 student files, of which this significant deficiency applies to 2, indicating an error rate of 100%. No other possible students to which this issue could have affected exist beyond those tested during the audit, as all withdrawn students were examined. Cause and Effect: For noted withdrawal calculations, the institution applied the percentage of earned aid to each type of disbursed aid individually, returning the remaining portion of each type of aid. However, the guidance stipulates that funds should be returned in a set order, returning the full amount of each type before moving to the next. In the return to Title IV process for the first student, the institution calculated an earned percentage of 50.0% based upon completed days. The student had been disbursed both subsidized and unsubsidized loans for the term. The director applied the 50.0% to each subsidized and unsubsidized awards to determine the monetary amounts of earned aid, returning the remaining $495 of subsidized and $866 unsubsidized loan disbursements to G5. The appropriate treatment would have been to return the full unearned portion of aid from the unsubsidized award. In the return to Title IV process for the second student, the institution calculated an earned percentage of 42.2% based upon completed days. The student had been disbursed both Pell and FSEOG for the term. The director applied the 42.2% to each Pell and FSEOG awards to determine the monetary amounts of earned aid, returning the remaining $2,156 of Pell and $146 of FSEOG disbursements to G5. The appropriate treatment would have been to return the full unearned portion of aid from the Pell award. Recommendation: The University should ensure that funds are returned in the prescribed sequence in the determination of the return of aid as designated by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University’s Vice President of Finance and Financial Aid Administrator recently attended a week-long workshop and received training to complete the R2T4 calculation via COD. The training was received after the infringements and a plan has been adapted to utilize COD for future R2T4 calculations and sequence. The school calendar has been updated in COD for correct future calculations and sequence.

Categories

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 508225 2024-003
    Significant Deficiency Repeat
  • 508226 2024-004
    Significant Deficiency Repeat
  • 508227 2024-005
    Significant Deficiency
  • 508228 2024-003
    Significant Deficiency Repeat
  • 508229 2024-004
    Significant Deficiency Repeat
  • 508230 2024-005
    Significant Deficiency
  • 508231 2024-002
    Significant Deficiency Repeat
  • 508232 2024-003
    Significant Deficiency Repeat
  • 508233 2024-004
    Significant Deficiency Repeat
  • 508234 2024-005
    Significant Deficiency
  • 1084667 2024-003
    Significant Deficiency Repeat
  • 1084668 2024-004
    Significant Deficiency Repeat
  • 1084669 2024-005
    Significant Deficiency
  • 1084670 2024-003
    Significant Deficiency Repeat
  • 1084671 2024-004
    Significant Deficiency Repeat
  • 1084672 2024-005
    Significant Deficiency
  • 1084673 2024-002
    Significant Deficiency Repeat
  • 1084674 2024-003
    Significant Deficiency Repeat
  • 1084675 2024-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $759,934
84.063 Federal Pell Grant Program $345,636
84.033 Federal Work-Study Program $17,699
84.007 Federal Supplemental Educational Opportunity Grants $10,954