Finding Text
Finding 2024-001 – Significant Deficiency: Special Tests And Provisions – Return Of
Title IV Funds – Compliance and Control Finding
ALN 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Per 34 CFR 668.22(j)(1), an institution must return the
amount of Title IV funds for which it is responsible under 34 CFR 668.22(g) as soon as possible
but no later than 45 days after the date of the institution’s determination that the student
withdrew as defined in 34 CFR 668.22(l)(3).
Condition: The University did not return Title IV funds within the 45-day time period for 1
student tested in our sample population.
Cause: Controls over compliance put in place by management were not operating effectively as
it relates to return of Title IV funds.
Effect: The University’s controls did not prevent the errors noted during the return of Title IV
funds.
Questioned Costs: $1,559 of known questioned costs were identified in our testing sample.
Likely questioned costs did not exceed $25,000.
Context: The University provided a listing of all students that withdrew during the academic
period, which totaled 68 students. In a statistically valid sample of 7 students that withdrew,
the University did not return Title IV funds during the required time period for 1 student
tested.
Identification As A Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend that management review its processes and controls
surrounding this compliance requirement to ensure that the control is appropriate and
operating effectively to support that the University is in compliance with the requirements of its
federal program.
Views Of Responsible Officials: During the 2023-2024 academic year, Financial Aid
employees attended a training over return of Title IV funds, in which they became aware that
students who received all incomplete ‘I’ grades for a term had 30 days following that term to
complete the courses. If those courses remained incomplete at the end of the 30 days, they
should be treated the same as students with all F grades. At that time, financial aid must
determine if they are required to complete a return of funds for that student. After the training,
funds were returned to Title IV for students who received all ‘I’ grades for the fall 2023
trimester. Total questioned costs related to this amounted to $1,559. The University remains
aware of the rules surrounding return of funds for students with all ‘I’ grades and will continue
to attend Student Financial Aid trainings.