Finding Text
Finding 2025-004 - Significant Deficiency: Special Tests and Provisions - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.268, 84.007, 84.063, 84.379 Criteria: Under federal Return to Title IV (R2T4) requirements, an institution must return any aid required to be returned to the Department of Education within 45 days of the date of the institution’s determination that a student withdrew from the institution. Condition: In our nonstatistical sample of 20 students tested for R2T4 compliance requirements, we noted one student whose Title IV return was not completed within the 45-day required timeframe. Cause: The University did not have sufficient internal controls to ensure timely processing of Return to Title IV (R2T4) funds. Specifically, existing procedures did not include adequate monitoring to verify that all unearned Title IV funds were returned within the 45-day timeframe following the University’s determination of withdrawal. Effect: Failure to return unearned Title IV funds within the required timeframe results in noncompliance with R2T4 regulations, which mandate that institutions return unearned Title IV funds within 45 days of the date the institution determined the student withdrew. Questioned Costs: None. Context: During the testing performed, it was noted for one student, the Title IV funds were returned 84 days after the withdrawal determination date. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend the University strengthen controls over the R2T4 return process by implementing a tracking or alert system to flag upcoming R2T4 return deadlines to ensure the 45-day requirement is met and conducting periodic internal audits to monitor compliance and identify any delays in return processing. Views Of Responsible Officials: Management concurs with the finding. The University is revising its procedures to ensure timely processing of all required R2T4 returns and is implementing additional internal controls and monitoring steps to ensure compliance with the 45-day return requirement. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services