Finding Text
Criteria 34 CFR 668.22(a) and 34 CFR 668.22(e) When a recipient of Title IV 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 aid earned by the student as of the student’s withdrawal date. The amount of Title IV assistance that is earned by the student is calculated by determining the percentage of aid earned by the student and applying the percentage to the total amount of Title IV assistance that was disbursed and that could have been disbursed to the student. 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. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section 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 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (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. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance– During testing over Return of Title IV requirements, the following exceptions were noted: The District inaccurately calculated the Return of Title IV funds for 3 out of the 60 students due to an error in counting the calendar days completed and the total calendar days in the period. Of the 3 errors noted, 1 student received a post-withdrawal disbursement when in fact, there should have been a return of funds back to ED. The District did not return the institution’s portion of the required return in a timely manner for 2 out of the 60 students. Questioned Costs There are no questioned costs associated with the condition identified. Context There were 997 Return of Title IV calculations performed during the year ended June 30, 2025. Effect The District is not in compliance with the Federal Return of Title IV requirements described in the OMB Compliance Supplement. Cause The District’s internal controls were not sufficient to ensure that the Return of Title IV funds were calculated timely and accurately, and returned in a timely manner. Repeat Finding (Yes or No) No Recommendation The District should strengthen internal controls over the review of Return of Title IV calculations to ensure that calculations are accurate, and funds are returned in a timely manner. Views of Responsible Officials and Corrective Action Plan We concur. The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehensive review to assess processes, staffing, and systems to ensure ongoing compliance and improvement.