Finding Text
Criteria or Specific Requirements OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: * For five of the sixty students tested, the District inaccurately calculated the Return to Title IV funds which resulted in the District returning the incorrect amount of funds to ED. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 451 Return to Title IV calculations during the year ended June 30, 2025. Repeat Finding (Yes or No) Yes, see prior year finding 2024-001. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner. Views of Responsible Officials and Corrective Action Plan The District acknowledges that deficiencies in internal controls over the Return to Title IV calculation process resulted in inaccurate calculations. The District has reviewed the identified calculations and corrected all errors. Return to Title IV policies and procedures will be updated and a standard process is to be completed for every calculation. The District will implement a mandatory secondary review of all Return to Title IV calculations prior to processing returns or post-withdrawal disbursements.