Finding Text
Finding #: 2024-001
Student Financial Assistance Cluster (Various Assistance Listing Numbers)
Award year ended June 30, 2024
Federal Agency: U.S. Department of Education
Type of Finding: Special Tests and Provisions - Return of Title IV Funds
Noncompliance and Internal Control over Compliance (Material Weakness)
Criteria:
Pursuant to the 34 CFR 668.22(j)(2), an institution is required to 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 to allow for the timely calculation and return of
Title IV funds as required. Pursuant to the 34 CFR 668.22(e), an institution is required to calculate the
amount of Title IV assistance earned by the student once the institution has determined the withdrawal date
in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required
to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned
Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total
institutional charges incurred by the student for the payment period or period of enrollment multiplied by the
percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34
CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with
deadline dates established by the U.S. Department of Education (Secretary), through publication in the
Federal Register, other reports and information the Secretary requires and shall comply with the procedures
the Secretary finds necessary to ensure that the reports are correct.
Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is
responsible as soon as, but no later than 45 days, after the date of the institution's determination that the
student withdrew.
Condition/Context:
During our testing at the University, we noted one instance out of 12 students tested in which the University
did not complete the return of Title IV funds as calculated within the 45-day requirement as noted in the
Federal Regulations.
Effect
The University was not compliant with the timeliness rules for one student in our sample.
Cause
The cause of the delay in performing the return was due to the substantial irregularity in the manner in
which a member of the faculty updated the student’s record. The student was not reported as having exited
by the faculty when the exit took place, but instead the faculty gave her a grade that reflects a withdrawal
took place instead of grading with an expected FW/F/NC. As such, the student’s record fell outside the
University’s discovery range for identifying unofficial withdrawals.
Questioned Costs:
None noted.
Identification as a Repeat Finding:
This is not a repeat finding.
Recommendation
We recommend the University’s management update the internal control procedures in place to identify
student’s that have withdrawn without providing notification.
Views of Responsible Officials:
Management agrees with the finding.