Finding 1186704 (2025-005)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-26

AI Summary

  • Core Issue: The College failed to return unearned Title IV funds within the required 45-day timeframe after a student's withdrawal.
  • Impacted Requirements: Compliance with 34 CFR 668.22(j)(1) and 34 CFR 668.173(b) regarding timely return of Title IV funds.
  • Recommended Follow-Up: Refine the process for monitoring student withdrawals and ensure timely calculations and returns of Title IV funds.

Finding Text

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The College has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 5, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 266 days. Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 5 students selected for testing, 1 student, or 20% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required timeframe. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that the College consider refining its process for completing and reviewing Return of Title IV calculations to help ensure funds are returned to the Department of Education within the required timeframe. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Corrective Action Plan: Because several issues related to compliance requirements surrounding enrollment status changes were identified in this process, we have developed a unified reporting tracking system to ensure the Registrar, the Office of Student Financial Assistance, and the Office of Fiscal Affairs all have visibility into the requirements when students leave the institution. This report will show all students identified by the registrar as having withdrawn, the date of determination, and the deadlines for NSLDS reporting, Exit Counseling, and R2T4 actions if necessary. This report will be visible to all three offices, and will identify when Title IV friends must be returned, automate the identification of the due dates for the return of Title IV funds, and timestamp the completion of the return of the funds, ensuring each action is taken within the required timeframe. It will improve oversight of this process as the status of the return of these funds will be visible to several staff members across several functions. Further, the Financial Aid office will identify an additional staff member to grant access to this report to assist the Director in ensuring Title IV funds are returned within the required timeframe moving forward. Timeline for Implementation of Corrective Action Plan: This report is currently under construction and will be fully implemented by Apr 1 2026.

Categories

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Other Findings in this Audit

  • 1186697 2025-001
    Material Weakness Repeat
  • 1186698 2025-002
    Material Weakness Repeat
  • 1186699 2025-003
    Material Weakness Repeat
  • 1186700 2025-003
    Material Weakness Repeat
  • 1186701 2025-004
    Material Weakness Repeat
  • 1186702 2025-005
    Material Weakness Repeat
  • 1186703 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $11.34M
84.063 FEDERAL PELL GRANT PROGRAM $3.77M
84.033 FEDERAL WORK-STUDY PROGRAM $88,187
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $87,146
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $16,594
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $0