Finding Text
Information on the federal program – Department of Education – Federal Pell Grant
Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268
Criteria or specific requirement – Special Tests and Provisions - When a recipient of
Title IV grant or loan assistance withdraws from a University during a payment period
or period of enrollment in which the recipient began attendance, the University must
determine the amount of Title IV aid earned by the student as of the student’s
withdrawal date. If the total amount of Title IV assistance earned by the student is
less than the amount that was disbursed to the student or on his or her behalf as of
the date of the University’s determination that the student withdrew, the difference
must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of
enrollment. (34 CFR Sections 668.22(a)(1)-(3)).
Condition – When students withdrew either officially or unofficially, the University did
not always return unearned Title IV aid timely. There were also three incorrect
calculations of returned funds for students that withdrew during the term.
Questioned costs – $1,909
Context – Out of 4 students tested, 2 students who withdrew during the audit period
tested had funds returned late. 3 out of the 4 students tested also had inaccurate
calculations. These were all corrected as part of the audit process.
Effect – Return of Title IV funds were not performed timely. Incorrect amount of
unearned Title IV funds returned.
Cause – This was an oversight by the University. R2T4 calculations were not reviewed
timely and for accuracy due to turnover at the director of financial aid position.
Identification as a repeat finding, if applicable – 2023-001
Recommendation – We recommend an individual in financial aid with the appropriate
level of experience periodically review R2T4 calculations and returns to help ensure
that internal controls over such a process can operate effectively and achieve
compliance. We also recommend the University implement controls to track and
remind when returns need to be returned once the withdrawal determination has
been made.
Views of responsible officials and planned corrective actions – Management is in
agreement with this finding. Moving forward, for each year, when the academic
calendar is released prior to the beginning of the fall semester, The Office of
Financial Aid and Scholarships will immediately determine the dates and number of
days used for the R2T4 calculations. The individual responsible for preparation of the
calculations has signed up for R2T4 training from NASFAA and will also attend
PowerFAIDS training related to R2T4. In addition, another employee within the
financial aid office is attending R2T4 training to ensure the financial aid office is
appropriately cross-trained and to provide an additional layer of review. The Director
of Financial aid has implemented a weekly review of R2T4s to ensure funds are
returned properly and there are no lapses in timelines.