Finding Text
Finding No. 2024-003 Timely Return on Title IV Funds
Federal Program
ALN 84.063 Federal Pell Grant Program
Name of Federal Agency
U.S. Department of Education
Category
Other matters – N. Special test Return of Title IV Funds
Significant deficiency of internal controls over compliance
Criteria
Under 34 CFR § 668.22(j), An institution must return the amount of title IV funds for which it is responsible under paragraph (g) as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew.
Condition found
In testing compliance with the return of Title IV funds requirement, we noted three (3) cases, or eight percent
(8%), of the sample selected which included students that received Pell and Direct loans, in which the University
failed to return the total corresponding refund within 45 days from the date the University determined that the
student withdrew, dropped-out, or failed to attend to the University, as follows:
Finding
Number
Related Audit
Compliance
Requirement
Student
Identifier OPEID
Pell
Disbursed
($)
Pell
Underpayment
($)
Pell Overpayment
($)
Direct
Loan
Disbursed
($)
Direct
Loan
Underpayment
($)
Direct
Loan Overpayment
($)
2024-003
Special Tests -
Timely Return of
Title IV Funds Student 1 1072401 $ 3,698 $ - $ - $ - $ - $ -
2024-003
Special Tests -
Timely Return of
Title IV Funds Student 2 1072401 $ 3,323 $ - $ - $ - $ - $ -
2024-003
Special Tests -
Timely Return of
Title IV Funds Student 3 1072401 $ 3,698 $ - $ - $ - $ - $ -
Cause
The return of tittle IV funds calculation process was conducted and completed on time in the Student Financial
Assistance (SFA) office. However, updating the SFA module in Ellucian (school ISIS) was not flagged as valid.
This omission meant that the University was unable to generate a cancelation payroll to close the transaction.
Effect
Failure to return unearned Title IV funds within the required 45-day timeframe can result in potential financial
liabilities for the institution, non-compliance penalties, and a negative impact on the institution's participation
in federal financial aid programs.
Questioned cost
None. The funds were returned.
Context
Three (3) of eleven (11) withdrawal forms from students who received Pell Grants from both campuses reviewed were not timely reimbursed to the Department of Education. The total amount of funds returned late was $5,688 out of a total of $10,512 for the campus of Miami.
Identification of a repeat finding
This is not a repeat finding from the immediate previous audit.
Recommendation
We recommend that the institution implement enhanced monitoring controls within the financial aid system to ensure that all return of tittle IV funds calculations trigger the necessary flags to prompt timely returns of unearned Title IV funds. Additionally, staff should be trained in monitoring these processes to prevent further delays in compliance with federal regulations. The institution should address the deficiencies noted and review all return of tittle IV funds processes to avoid recurrence and to ensure compliance.
Views of responsible officials and planned corrective actions
The University’s management agrees with this finding. Please refer to the corrective action plan on pages 60-63.