Finding Text
Criteria: 34 CFR 668.164(h)(2) requires that a Title IV credit balance must be paid directly to the student
or parent as soon as possible, but no later than – (i) 14 days after the balance occurred if the credit balance
occurred after the first day of class or a payment period; or (ii) 14 days after the first day of class of a
payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: The University did not pay Title IV credit balances to 3 students or parents in a timely manner.
Context: We selected a non-statistical sample of 60 students with disbursements for special tests and
provisions – disbursements to or on behalf of students testing, of which 41 students had Title IV credit
balances. For 3 out of the 41 credit balances, payments to the student or parent were made after the 14-day
requirement. The 3 instances were related to credit balances that were created in December 2023 and paid
out in January 2024.
Cause: Although the University has policies and procedures in place for the payment of Title IV credit
balances, there was a failure to follow its policies and procedures. Management indicated that the credit
balances were created in December, directly preceding the University’s holiday break. The University is
closed during this period and staffing is generally limited. Management followed its ordinary procedures
to pause disbursements prior to break to ensure the credit balances are paid to students or parents in a timely
manner. However, one staff member was unaware of this requirement and manually disbursed aid resulting
in credit balances for 3 students which required repayment during the holiday break.
Effect: Failure to timely pay Title IV credit balances to students or parents resulted in noncompliance with
the special tests and provisions – disbursements to or on behalf of students requirement.
Questioned Costs: None
Identification of a repeat finding: N/A
Recommendations: We recommend the University establish clear procedures to ensure timely and effective
communication with staff regarding alternative disbursement schedules.
Views of responsible officials: The University has an automated process in place to disburse aid daily. That
process is set to stop on a certain day before the University’s scheduled Winter Break to allow the refund
processing team time to generate and distribute refunds within the allotted timeframe and maintain
compliant with related regulations despite the University’s scheduled closure. According to established
procedures, the process was stopped as scheduled.
However, one of the University’s Financial Aid Counselors manually authorized and disbursed aid for a
small number of students after the process was halted for the semester because they were unaware of the
reason why aid was not disbursing, and they were attempting to help students who were calling the Financial
Aid office. Once management became aware of this issue, the Director of Financial Aid immediately
approached the staff member and explained the reason why the University stopped making disbursements.
The Director instructed the team member to not override these established controls and explained the
importance of adhering to the policies in place. The staff member acknowledged that they understood the
consequences of their actions and the need to adhere to policies.
In the future, the University will take extra steps to communicate with all team members when this control
is initiated prior to Winter Break to ensure collective understanding of the reason for pausing disbursement.