Finding Text
2024 – 001: Return of Title IV Funds Testing
Federal Agency: Department of Education
Federal Program: Student Federal Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various - 2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance
Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date.
In accordance with 34 CFR 668.22(b) and (d)(4),the institution must return those funds for which it is responsible under paragraph (a) of this section to the respective title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
An institution does not satisfy this requirement if—
(i) The institution's records show that the check was issued more than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance; or
(ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 45 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Condition: It was noted during our testing of R2T4 calculations that 17 of 40 students selected for R2T4 testing had an instance of non-compliance. Specifically, 12 students had excess returns totaling $2,404; one of those students also should have received a post-withdrawal disbursement of $124; three students had under returns of $22; and one student's return was not received within the 45-day time limit.
Questioned Costs: Excess returns exceeded under returns and missed post-withdrawal disbursement. Accordingly, there are not net questioned costs.
Context: During our audit procedures, we noted below instances for R2T4 testing:
- 1 of the 40 total students' Pell was not returned within the 45 days requirement due to human error.
- 16 of the 40 total students' R2T4 was incorrectly calculated.
Cause: The District does not have proper second review in place to ensure student awards are properly adjusted based on calculations performed.
Effect: The District is not returning the proper amounts to the Department based on the calculations performed.
Repeat Finding: Yes, 2023-001.
Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly
adjusted to the student’s account and the correct amounts are being returned to the Department.
Views of Responsible Officials: Management concurs with the finding.