Finding Text
Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year: P063P242037 - 2025, P007A243429 - 2025, P033A243429 - 2025, P268K252037 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment 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 a payment period or period of enrollment and the number of calendar days completed in that period. The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations and did not return Title IV funds within 45-days. Questioned costs: None. Context: During our testing of 40 R2T4 calculations, we identified that 15 had mechanically incorrect calculations by using the incorrect number of scheduled break days in the Spring term. Additionally, we identified 1 student with Title IV refund that was not returned within the 45-day requirement. Cause: The College was using the incorrect number of scheduled break days for Spring Term. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: Yes, 2024-003 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the College implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.