Finding Text
Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 34 CFR 668.22 (a)(1) through (a)(5), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV assistance earned by the student as of the student's withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution's determination that the student withdrew, the difference must be returned to the Title IV programs, and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post withdrawal disbursement. Condition - The School District does not calculate or process any post withdrawal disbursements for students that have withdrawn from the institution. Questioned Costs - Unknown If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - The School District does not maintain accurate cost of attendance calculations needed in order to determine the amount of the post withdrawal disbursements for students who withdrew during the fiscal year. Identification of How Questioned Costs Were Computed - N/A Context - During our discussion and testing of Return of Title IV Funds (R2T4) calculations, we identified that the institution did not process or offer post withdrawal disbursements to students who withdrew prior to the 60% mark of the semester in which tuition is charged to the student account. We identified two students from the population of withdrawn students who withdrew after the start of the semester and before tuition was applied. Although the students incurred costs, such as transportation, housing, books, etc. the School District did not process post withdrawal disbursements for the students. Cause and Effect - The institution’s R2T4 procedures did not include a review for post withdrawal disbursement eligibility. Staff were unaware of the requirement to offer and process post withdrawal disbursements for earned aid. Eligible students did not receive Title IV funds they had earned prior to withdrawal, resulting in potential underfunding and noncompliance with federal regulations. Recommendation - We recommend the School District revise its R2T4 procedures to include a formal review for post withdrawal disbursement eligibility and ensure timely notification and processing of earned aid. Staff should be trained on federal requirements related to post withdrawal disbursements. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is revising its R2T4 procedures to include a formal review of post-withdrawal disbursement eligibility and will ensure timely notification and processing of any earned aid. Staff are being trained on applicable federal requirements and the updated procedures to maintain full compliance.