Finding Text
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALNs 84.007, 84.033, 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Return of Title IV Funds - The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education (“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 668.173(b)). If a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for that payment period or period of enrollment. The institution must return those funds for which it is responsible under 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 (34 CFR section 668.21). If the total amount of Title IV grant or loan assistance, or both, that the student earned is greater than the total amount of Title IV grant or loan assistance, or both, that was disbursed to the student of on behalf of the student in the case of a PLUS loan, as of the date of the institution’s determination that the student withdrew, the difference between these amounts must be treated as a post-withdrawal disbursement. If outstanding charges exist on the student’s account, the institution may credit the student’s account up to the amount of outstanding charges with all or any portion of loan funds that make up the post-withdrawal disbursement in accordance with 34 CFR sections 668.164(d)(1), (d)(2), and (d)(3) only after obtaining confirmation from the student or parent in the case of a PLUS loan, that they still wish to have the loan funds disbursed to their account (34 CFR sections 668.22(a)(5) and (a)(6)(ii)(A)).
Condition – Refund calculation for a certain student selected for testing was appropriately prepared however, the University did not return funds to the ED within the required time frame for certain students selected for testing.
Cause – Insufficient internal controls and lack of administrative oversight over the return of Title IV funds.
Effect or Potential Effect¬ – The University is not in compliance with the required federal guidelines over the return of Title IV funds.
Questioned Costs – Below reporting threshold.
Context – For 1 of 3 students selected for testing, Title IV funds required to be returned were not submitted to the ED within the required time frame.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures to ensure that Title IV funds are returned within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will monitor internal controls to ensure that the return of Title IV funds is processed in accordance with federal regulations, specifically within the required 45-day timeframe after determining a student has withdrawn from the University. The University will establish a quarterly audit and monitoring system to review all Title IV fund returns, ensuring compliance with federal guidelines.