Finding Text
Criteria or specific requirement: 34 CFR 668.22(a)(1) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a period of enrollment that the recipient began attendance in, the institution must determine the amount of Title IV assistance that the student earned in accordance with 34 CFR 668.22(e) which states that the calculation to determine this is equal to the percentage of the period of enrollment that the student completed as of the withdrawal date if this date occurs before completion of 60% of the period of enrollment. The amount unearned by the student is the complement of this percentage and is required to be returned as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as described in 34 CFR 668.22(j)(1). The withdrawal date is the date by which the student began the withdrawal process or provided official notification to the institution of intent to withdraw. If the student ceased attendance without providing notification to the institution the midpoint of the period of enrollment should be used. If the student’s ceasing attendance is due to illness, accident, or other circumstance beyond the students control the withdrawal date is date the institution becomes aware of these circumstances, as described in 668.22(c). Further (j)(2) states an institution not required to take attendance must determine the withdraw date for students who withdraw without providing notification to the institution no later than 30. Criteria or specific requirement (continued): days after the end of the earlier of the period of enrollment, academic year in which withdrawal occurred, or education program for which the student withdrew. Additionally, per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain effective internal controls designed to reasonably ensure compliance with federal laws, regulations, and program requirements related to these awards. Condition: The College did not accurately determine student withdrawal dates, leading to incorrect Return of Title IV (R2T4) calculations. Additionally, withdrawals were not identified in a timely manner, and funds were not returned within the required 45-day period. The College also lacked internal controls to ensure the R2T4 process complied with federal regulations and guidelines. Questioned Costs: None. Context: During our testing, we identified exceptions in 7 out of 16 sampled student records. Specifically: • 5 students had incorrect withdrawal dates recorded. • 2 students had Return of Title IV (R2T4) calculations that were not accurately performed. • 3 students experienced delays in withdrawal determination beyond 30 days of their enrollment period, and for these same students, funds were not returned to COD within the required 45-day timeframe. Furthermore, the College lacks a formal review process to ensure adherence to federal laws, regulations, and program compliance requirements. Cause: The College did not establish precise controls to ensure compliance with federal laws, regulation and program compliance requirements over R2T4. Effect: The lack of an internal control to ensure compliance with federal requirements could result in errors going undetected by the College. Repeat Finding: Yes, 2023-005, 2023-008. Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. Additionally, we recommend the College implement a formal review process to ensure the R2T4 calculations being prepared timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Views of responsible officials: There is no disagreement with the finding.