Core Issue: The College did not return unearned Title IV funds within the required 45 days after a student withdrawal.
Impacted Requirements: This finding indicates a significant deficiency in internal controls and noncompliance with federal financial aid regulations.
Recommended Follow-Up: Implement improved internal controls and communication protocols to ensure timely processing of Title IV fund returns.
Finding Text
Finding 2025-005 Federal Assistance Listing Number: 84.268 Subprogram Number(s): 84.268 Federal Agency: U.S. Department of Education Program Name: Federal Direct Student Loans Type(s) of Compliance Requirements: Special Tests and Provisions Type of Finding: Internal Control over Compliance – Significant Deficiency; Noncompliance Criteria: Under the Return of Title IV Funds compliance requirement, institutions must return unearned Title IV funds to the U.S Department of Education within 45 days of the date the institution determines the student withdrew (or within 30 days for students who never began attendance). Condition: The College returned Title IV funds 79 days after the College became aware of the student's withdrawal. Cause: The College failed to process the return in a timely manner due to miscommunication between departments within the College. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Recommendation: We recommend that the College implement stronger internal controls and communication procedures to ensure timely return of Title IV funds within the required 45-day period. This includes establishing clear withdrawal notification protocols and monitoring processes.
Corrective Action Plan
Finding 2025-005 Corrective Action Plan The Finance team will collaborate with the Director of Financial Aid and the Registrar to strengthen the format of notifications to return Title IV funds within the required timeframe as outlined in the Federal Direct Student Loans Program. Anticipated Completion Date The corrective action plan is anticipated to be completed on or before August 31, 2026. Names of Contact People Responsible for Corrective Action Jeanne Cavalieri-Grover –Director of Fiancial Aid Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Karen West – Coordinator of Student Billing Jade Jackman – Registrar
Categories
Special Tests & ProvisionsStudent Financial AidSubrecipient MonitoringSignificant DeficiencyMatching / Level of Effort / EarmarkingInternal Control / Segregation of Duties