Finding Text
Compliance Area Student Financial Assistance Cluster – Special Tests and Provisions – Return of Title IV Funds (R2T4) Criteria or Requirement In accordance with 34 CFR 668.22, institutions must accurately determine the percentage of the payment period completed using the correct payment period start and end dates to calculate earned and unearned Title IV assistance. If a student withdraws before completing 60% of the payment period, the institution must determine the amount of unearned Title IV funds and return those funds within 45 days of the date of determination. Condition Found, Including Perspective During testing of 10 students who withdrew during the year ended June 30, 2025, we recalculated the Return of Title IV Funds (R2T4) determinations. Differences were identified in three of the 10 selections tested. In two of the three instances, the institution used an incorrect Spring 2025 term end date in the Colleague system when calculating the percentage of the payment period completed. As a result, the students were calculated at or above the 60% completion threshold and determined to have earned 100% of their Title IV assistance, when recalculation using the official academic calendar dates indicated that a return of funds was required. One additional instance resulted in a de minimis difference. Possible Asserted Cause and Effect The term end date configured in the Colleague system did not align with the institution's official academic calendar, and procedures were not in place to verify that system-configured term dates agreed to the approved academic calendar prior to performing R2T4 calculations. As a result, R2T4 determinations were not calculated using the correct payment period dates, which resulted in failure to identify and return unearned Title IV funds in certain instances. If the issue is systemic, additional students who withdrew during the Spring 2025 term may have been similarly affected. Questioned Costs Questioned costs related to the two affected students totaled approximately $5,800, representing Title IV funds that should have been returned based on recalculation using the official term dates. Final questioned costs may change pending management's review of the full withdrawal population for the Spring 2025 term. Statistical Validity A nonstatistical sampling approach was used. Therefore, results cannot be projected to the population; however, the error rate identified indicates the potential for similar noncompliance within the population of students who withdrew during the Spring 2025 term. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-003 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University reconcile system-configured term dates within Colleague to the officially approved academic calendar for all academic periods used for Title IV calculations. In addition, the University should perform a comprehensive review of students who withdrew during the Spring 2025 term to determine whether additional R2T4 recalculations and returns are required. Procedures should be implemented to periodically verify that system term dates align with official academic records prior to performing R2T4 calculations.