Finding Text
Criteria or Specific Requirements
34 CFR section 668.173(b):
Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student
Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but
no later than 45 days after the date the institution determines that the student withdrew.
Returns by check are late if the check is issued more than 45 days after the institution
determined the student withdrew or the date on the canceled check shows the check was
endorsed more than 60 days after the date the institution determined that 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
Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV
requirements, it was noted that funds for 5 of 60 Return to Title IV calculations were returned
outside of the required timeframe.
Questioned Costs
None noted.
Context
A non-statistical sample of 16 return of Title IV calculations were tested out of a total population
of 101 return of Title IV calculations for West Hills College – Coalinga.
A non-statistical sample of 44 return of Title IV calculations were tested out of a total population
of 269 return of Title IV calculations for West Hills College – Lemoore.
Effect
In 5 of the 44 calculations tested for West Hills College - Lemoore, the Return to Title IV funds
were returned outside of the required timeframe.
Cause
The District did not implement procedures to ensure that the return to Title IV funds were
returned in a timely manner.
Repeat Finding
No.
Recommendation
The District should establish effective controls to ensure the return of funds occurs within 45
days from the date the institution determines the student withdrew from all classes and that the
withdrawal determination is performed within the required timeframe.