Finding Text
Special Tests and Provisions – Return to Title IV: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance. Criteria or specific requirements: 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition: During our procedures over Return to Title IV requirements, the following deficiencies were noted: 6 of 31 Return to Title IV calculations were performed outside of the allowable time frame. 3 of 31 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Cause : The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect: Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs: Questioned costs include $4,210 of funds that were not returned to U.S. Department of Education. Context: The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 31 R2T4 calculations out of the College’s total population of Return to Title IV testing. Identification as a repeat finding: Previously reported as finding 2022-005. Recommendation: The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the academic period. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.