Finding Text
Finding 2025-004 - U.S. Department of Education (ED) Student Financial Assistance Programs - Untimely Return of Title IV Funds (significant deficiency): Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.22 (j), (1) institutions must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Condition – During our review of the Return of Title IV Funds (R2T4) calculations, we identified one (1) student for whom the institution did not return unearned Title IV funds within the required 45-day timeframe. The funds were not returned until 102 days after the institution’s date of determination (ED), exceeding the regulatory deadline. Cause – The late return appears to have resulted from insufficient processes to identify and communicate unofficial withdrawals between the Registrar’s Office and the Financial Aid Office in a timely manner, resulting in delayed initiation of the Return to Title IV (R2T4) process. Effect - The institution was not in compliance with federal R2T4 return requirements. Untimely returns reflect weaknesses in the institution’s internal control over Title IV administration and may affect administrative capability under 34 CFR § 668.16. Questioned Costs - $0 Perspective – Returning unearned Title IV funds within 45 days is a core compliance requirement. Institutions must demonstrate the ability to promptly identify withdrawals, calculate R2T4 amounts, and process returns to maintain eligibility for participation in Title IV programs. Repeat Finding – No Auditor’s Recommendation - The institution should implement a formal R2T4 tracking system and strengthen coordination between departments. View of Responsible Officials – Going forward, the Registrar will complete a notice that a student withdrawal with a clear date when the student leaves the college. This notice will be forwarded to Financial Aid and responsibility shift to this department to ensure that the funds are returned within the allowed time limit.