Finding Text
Special Tests and Provisions – Return of Title IV Funds Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct funded by the U.S. Department of Education (ED) Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Award Identification Number: P007A240575, P033A240575, P063P241174, P268K251174 Award Year: 2024-2025 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. 34 CFR 668.22(i) Returns of Title IV funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution’s agreements with other state agencies or private agencies a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition Significant Deficiency in Internal Control over Compliance and Noncompliance – During testing over Return of Title IV requirements, the following deficiencies were noted: The District inaccurately calculated the Return of Title IV funds for 32 out of the 60 students due to improper counting of days in the academic term. Of these 32 errors, 2 of the calculations performed in the Fall utilized the regular Fall term dates as opposed to the correct, late start dates. The remaining 30 errors noted that the District erroneously counted the number of days in the Spring break as 6, as opposed to the correct 5 day break. The District inaccurately calculated 1 student’s institutional charges which resulted in the original calculation as a return of funds. With the corrected institutional charges, the result would have a post-withdrawal disbursement. The District did not return funds for 4 of the 60 students. The District did not return funds timely (within 45 days) for 4 of the 60 students. The District returned the incorrect amount of funds for 1 of the 60 students. The District did not return funds in the proper order for 1 of the 60 students. Questioned Costs There are no questioned costs associated with the condition identified. Context There were approximately 548 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 did not implement procedures 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) Yes, see 2024-001. 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 and in the correct order.