Finding Text
Assistance Listing, Federal Agency, and Program Name ALNs 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Significant deficiency Repeat Finding No Criteria The University has 45 days from the date the University determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds to the Department of Education. Withdrawal dates are defined as the time when the student officially withdrawals or expresses notification to withdrawal or, if the student does not officially withdraw, the date the University determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition The University did not return all Title IV funds in a timely manner to the Department of Education for certain students who withdrew during the year. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Of the 11 students tested, for 3 students, the University did not calculate the required return in a timely manner and did not return funds to the Department of Education within the required time frame. Cause and Effect The University did not have adequate controls to return funds to the Department of Education after the calculation had been performed in accordance with the regulations, which resulted in late returns. Recommendation We recommend implementing a control to ensure that all Title IV funds are returned within the required time frame. Views of Responsible Officials and Planned Corrective Actions The primary underlying cause of this issues was the significant lack of training, guidance, and onboarding support provided by Anthology during the implementation of the Anthology Student system. Prior to golive, the University was unable to fully test the Title IV awarding, disbursing, and adjustment processes because file transmissions to COD (Common Origination and Disbursement) can only be executed using live data. This limitation prevented staff from validating system behavior in a testing environment and further hindered the understanding of the required processes, procedures, and communication workflows between Anthology Student and COD. As a result, staff lacked critical knowledge needed to ensure Title IV transactions—including those tied to Return to Title IV (R2T4) calculations—were correctly generated and transmitted. Corrective action has already been implemented. The Financial Aid Office now manually reviews and verifies all Title IV awarding, disbursement, and adjustment transactions—including those related to R2T4—to ensure successful submission to COD. Once the R2T4 calculation has been completed in COD, the Financial Aid Advisor manually updates the student’s account in Anthology Student. The Business Office then posts the corresponding adjustment to the student ledger. After the Business Office posts the Title IV activity, the Financial Aid Advisor manually processes the related adjustments and disbursements through COD to ensure the timely return and/or disbursement of funds associated with the R2T4 calculation. These manual oversight procedures will remain in place until the University receives additional and adequate training from Anthology that ensures consistent and reliable electronic transmission between Anthology Student and COD.