Finding Text
Finding 2025-005 - 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, when a student receive less Title IV aid than the amount earned, the school must offer the student a post-withdrawal disbursement (PWD) of the earned aid the student did not receive. Condition: In our nonstatistical sample of 20 students tested for R2T4 compliance requirements, we noted two students who were eligible for a post-withdrawal disbursement. However, the University could not provide evidence that it offered the required post-withdrawal disbursement to either student. Cause: The University did not have sufficient internal controls to ensure that all students eligible for post-withdrawal disbursements were appropriately notified. Existing procedures did not require documentation of post-withdrawal disbursement offers or adequate monitoring to verify that offers were issued and retained in the student record. Effect: Failure to properly offer a post-withdrawal disbursement results in noncompliance with federal R2T4 requirements, potentially denying students access to Title IV aid they were entitled to receive. Questioned Costs: None. Context: For the two students where no post-withdrawal disbursement offer could be located by the University, the students were eligible to receive $493 of Pell and $631 of direct unsubsidized loans. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend the University implement documentation controls requiring staff to retain evidence of all post-withdrawal disbursement offers in the student file and develop monitoring or review mechanisms to verify that all required post-withdrawal disbursement offers are completed and documented in compliance with federal regulations. Views Of Responsible Officials: Management concurs with the finding. The University is revising its procedures to ensure all post-withdrawal disbursement offers are properly issued and documented and will implement additional controls and staff training to ensure future compliance with federal R2T4 requirements. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services