Finding Text
Criteria or Specific Requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the returns of Title IV funding were calculated correctly and resulted in improper returns. Additionally, one return was not made timely. Cause – The correct calculations were not updated in the student system to ensure the correct amounts were returned. Effect or Potential Effect – The University returned the incorrect amount of funds and did not return funds timely. Questioned Costs – ALN 84.268 – $2,730. Calculated using amounts under-returned to the Department of Education. Context – Out of the population of 179 students who withdrew, 25 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Two students had incorrect calculations due to incorrect days completed or in the term; one return had the incorrect federal awards used and funds for one return was not made timely. Identification as a Repeat Finding, if applicable – 2024-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly, funds are returned in the correct order, and post-withdrawal disbursements are made correctly. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the finding related to Return of Title IV (R2T4) calculations and the timeliness of returns. The University recognizes the importance of accurate calculations and timely processing in compliance with federal regulations. The errors identified were primarily related to inaccuracies in determining the total number of days in the payment period and ensuring the correct data elements were consistently applied within the student information system. While corrective actions were implemented following the prior audit, management has determined that additional controls and validation procedures are necessary to ensure consistent accuracy. To address this issue, the University has implemented and will continue to implement the following corrective actions: 1. System Configuration Review and Validation – The student information system configuration for R2T4 calculations has been reviewed and updated to ensure that academic calendars, including term dates and scheduled breaks, are accurately reflected. These configurations will be validated prior to the start of each term. 2. Enhanced Calculation Review Process – A secondary review of a sample of R2T4 calculations will be performed to verify the accuracy of key inputs, including days attended, total days in the term, and applicable aid types. 3. Standardized Procedures and Checklists – The University has developed standardized procedures to ensure consistent application of federal requirements, including proper ordering of funds and treatment of post-withdrawal disbursements. 4. Timeliness Monitoring – Processes have been enhanced to track and monitor the timing of R2T4 calculations and returns to ensure compliance with required deadlines. 5. Training and Staff Development – Financial aid staff have received additional training on R2T4 requirements, with a focus on calculation components, system inputs, and regulatory updates. 6. Ongoing Quality Assurance Reviews – Periodic internal reviews will be conducted to assess compliance and identify any discrepancies for prompt correction. Management believes these enhanced controls and monitoring procedures will address the root causes of the finding and prevent recurrence.