Finding Text
Criteria: 34 CFR 668.164(h)(2) requires that a Title IV credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred after the first day of class or a payment period; or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.Condition: The University did not pay all Title IV credit balances to students or parents within the 14 days. Context: We selected a non-statistical sample of 60 Title IV credit balances. For 9 out of the 60 credit balances, payments to the student or parent were made after the 14-day requirement. In all instances identified, the Title IV credit balances were ultimately paid to the student or parent. Cause: Although the University has policies and procedures in place over the payment of Title IV credit balances, management indicated that responsibility for reviewing and processing Title IV credit balances transferred from the Business Office to the Student Accounts during the year. This transition was not supported by sufficient training or clarification of compliance requirements, resulting in misunderstandings and inconsistent execution of required procedures. Effect: Failure to timely pay Title IV credit balances to students or parents resulted in noncompliance with the special tests and provisions – disbursements to or on behalf of students requirement. Questioned Costs: None Identification of a repeat finding: This is a repeat finding. See prior year finding 2024-006. Recommendations: We recommend the University strengthen its controls over the review and processing of Title IV credit balances to ensure refunds to students or parents are issued within the required 14-day timeframe. In addition, when responsibilities related to Title IV compliance are transferred between departments, the University should implement procedures to ensure staff receive appropriate training, roles and responsibilities are clearly defined, and compliance requirements are communicated to support consistent execution of required procedures. Views of responsible officials: The officials responsible for Student Accounts acknowledge that certain student financial aid refunds were processed outside the 14-day federal deadline, primarily due to insufficient Title IV training during the initial transfer of responsibilities to Student Accounts. While a standard operating procedures (SOP) exists within the current refunds training, it is limited, focusing primarily on the reports and some of federal requirements but does not provide sufficient detail on regulations, reviews, approvals, and timelines. Student Accounts has already taken steps to address and correct the misinformation, but additional improvements are still needed. The SOP for refunds is currently in progress to fully incorporate all necessary items to ensure better and clearer training guidelines. Mandatory Title IV refund training will be provided to all Refund Representatives and included in onboarding for new hire. We shall set established expectations set for all individuals involved in the process, including their delegates, to ensure accountability and consistent application of procedures. Ongoing collaboration with Financial Aid will ensure procedures are consistently applied, questions are addressed, and staff remain current with requirements. These actions are expected to ensure compliance with the 14-day federal requirement, strengthen staff competency, and support continuous improvement in refund processing.