Finding Text
Incorrect Term Dates Used in R2T4 Calculations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education and U.S. Department of Health and Human Services; Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.379, 84.268 and 93.364; Award Numbers P007A242029, P033A242029, P038A172029, P063A232029, P063P240235, P379T240235, P268K240235 and P268K250235. Criteria. Under 34 CFR §668.22, institutions are required to calculate the percentage of Title IV aid earned based on the number of calendar days completed in the payment period or period of enrollment, beginning with the actual first day of the term as defined by the institution’s academic calendar. Condition. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. Cause. Controls were not in place to ensure the term start date used in R2T4 calculations was verified against the academic calendar prior to processing. Effect. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Questioned Costs. There were questioned costs of $96. Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.