Finding Text
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – 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. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination.
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition: The University did not properly calculate the amounts to be returned and did not timely return funds to ED for certain students tested.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with the return of Title IV funds requirements.
Questioned Costs: Sampled questioned costs: $2,003; total questioned costs: indeterminable.
Context: For 1 of 17 students tested, the University did not properly calculate the amount of Title IV aid to be returned.
For 1 of 17 students tested, the University did not return funds to ED within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-008.
Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately and funds are returned to the ED within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed.