Finding Text
Criteria Under 34 CFR 668.164(h)(2)(i), a Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than fourteen (14) days after the credit balance occurs, if the credit balance arises after the first day of class of the payment period. Condition From a sample of seventeen (17) students with Title IV credit balances subject to the fourteen (14) days refund requirement, we identified thirteen (13) students with at least one instance of a late refund, totaling 14 instances in which credit balance refunds were not issued within the required timeframe. Cause The condition occurred because, during the academic year 2024–2025, the University transitioned to a new ERP system, Ellucian Banner, introducing new and modified processes that required additional training. Concurrently, responsibility for key post-disbursement activities shifted from the Accounting office to the Bursar & Collections office, requiring new coordination between both areas. Although the University had defined a monitoring process among the cross-functional offices involved in tracking Title IV credit balances, including a calendar outlining required activities and the timelines each department must follow after the disbursement run, the Bursar office, as it assumed these expanded responsibilities, faced an adjustment period and did not have sufficient staffing to execute these procedures consistently within required timeframes during the transition period. Effect The failure to disburse credit balances within the prescribed regulatory period resulted in noncompliance with federal requirements. Consequently, affected students did not receive timely access to their Title IV funds, as required. Questioned Costs None. Recommendations We recommend that the University evaluate and address the staffing limitations within the department responsible for key post-disbursement monitoring procedures. This may include allocating temporary support, reallocating internal personnel during peak periods, or reviewing workload distribution to ensure all required tasks outlined in the monitoring calendar are completed timely. Additionally, Management should implement a contingency plan for periods of reduced staffing to ensure continuity of the established monitoring process and prevent delays in processing Title IV credit balance refunds. Views of Responsible Officials Refer to Management's unaudited corrective action plan.