Finding Text
FINDING 2025-002: LATE RETURN OF TITLE IV FUNDS Condition In four of the thirty-two student files tested for compliance with return of Title IV funds requirements, we identified a refund that was not made within the required timeframe. The students involved were #s 31, 41, 56, and 58. We expanded our return of Title IV funds testing to include all students who withdrew during the fiscal year, which included an additional one-hundred and eighty-nine (189) Title IV recipients. From this additional sample, we identified fifteen late refunds. The students’ ID numbers are 66970, 15339, 79844, 86138, 84556, 83944, 79353, 71748, 5918, 68148, 88625, 85938, 83212, 63987, and 89290. Criteria If the total amount of Title IV assistance earned by a student who has withdrawn is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. If a recipient of Title IV assistance does not begin attendance in the payment period, all disbursed Title IV funds must be returned within 30 days of the school becoming aware that the student will not or has not begun attendance. A student is considered to have not begun attendance in a payment period or period of enrollment if the school is unable to document the student’s attendance at any class during the payment period or period of enrollment. Cause The untimely return of Title IV funds appears to have resulted from procedural lapses within the Institution’s financial aid processes, as well as staff turnover in the Financial Aid Office. These factors may have contributed to gaps in oversight and delays in the consistent execution of required return procedures. The Institution didn’t have sufficient processes in place to ensure refunds were made timely when turnover occurred and or to identify when certain procedures were not being performed. Effect and Questioned Costs A Return of Title IV funds was not made in a timely manner. Details are included in Summary Schedule C of this report. As a result of this finding, the Institution has exceeded the compliance thresholds that are defined in 34 CFR 668.173(c). Recommendation The Institution should implement procedures to ensure that, in the future, Title IV refunds are made in accordance with the federal regulations. The Institution must submit an irrevocable letter of credit acceptable and payable to ED equal to 25% of the returns the Institution made during the year ended June 30, 2025. Views of Responsible Officials The Institution concurs with this finding.