Finding Text
Special Tests and Provisions – Return to Title IV
Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268
US Department of Education
Significant Deficiency and Nonmaterial Noncompliance
Criteria or specific requirements
34 CFR section 668.173(b)
Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic
fund transfers initiated to 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 668.22(j)(2):
An institution must 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.
34 CFR section 668.22(c):
If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by
the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as
determined by the institution, that the student otherwise provided official notification to the school, in
writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing
official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if
applicable, the period of enrollment; (4) if the institution determines that a student did not begin the
withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident,
grievous personal loss or other circumstances beyond the student’s control, the date the institution
determines is related to that circumstance; (5) if a student does not return from an approved leave of
absence, the date that the institution determines the student began the leave of absence; or (6) if the
student takes an unapproved leave of absence, the date that the student began the leave of absence.
Condition
During our procedures over Return to Title IV requirements, the following deficiencies were noted:
7 of 13 Return to Title IV calculations were performed outside of the allowable time frame.
1 of 13 withdrawn students did not have a Return to Title IV calculation performed.
2 of 6 instances where funds were returned beyond the required time frame.
Cause
The College did not implement procedures to ensure that the Return to Title IV funds were performed
accurately and returned in a timely manner.
Effect
Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the
above criteria.
Questioned costs
None identified. While the determinations were performed late, no unreturned funds were noted. Context
The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan
Programs timely. A nonstatistical sample of 13 withdrawn students out of 40 selected from the College’s
total population.
Identification as a repeat finding
Previously reported as finding 2023-004.
Recommendation
The College should implement procedures to ensure that the student withdrawal calculations are
preformed timely and return funds within 30 days from the end of the student’s period of enrollment.
View of responsible officials and corrective action plan
Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be
implemented.