Finding Text
Finding 2025-005 – N. Special Tests and Provisions – Return of Title IV Funds Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.063, 84.268, 84.379) Criteria or Specific Requirement – Title IV regulations (34 CFR 668.22) require institutions to return the unearned portion of grants or loans to the student based on the calculated percent completed by the student. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition – Certain return of Title IV (“R2T4”) calculations were not accurately prepared. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – Return of funds was not properly calculated and returned. Questioned Costs – None. Context – For 2 of 2 students tested, the University did not accurately determine the amount to return. Indication of Repeat Finding - This is a repeat of prior year Finding 2024-005. Recommendation – We recommend that the University enhance its procedures and internal controls related to the return of Title IV funds calculations. Views of Responsible Officials – After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The R2T4 process has been working correctly following our R2T4 policy to make sure the days are correct in the system before the R2T4 is submitted. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break.