Finding Text
Information on Federal Program: United States Department of Education. Student Financial Assistance Cluster. Federal Assistance Listing Number 84.063 – Federal Pell Grant Program; 84.268 – Federal Direct Loan Program Compliance Requirements: Return of Title IV Funds Criteria: (34 CFR 668.22(a)(1)) When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.Condition: For the year ended May 31, 2025, we reviewed return of title IV funds requirements for students who received title IV program funds and withdrew from the institution during the audit period and noted three (3) instances where the institution used the incorrect calculation resulting in funds due to the Department, one (1) instance where the institution used the incorrect calculation resulting in too much funds returned to the department, and one (1) instance where the student received financial aid but never began attendance. Cause: No cause could be determined. Effect: Students retained the incorrect amount of title IV funds after a withdraw. Questioned Costs: $7,368 in 24-25 Unsubsidized Federal Direct Loan program funds under refunded to the department, $15 in 24-25 Federal Pell Grant Program Funds under refunded to the department, and $217 in 24-25 Unsubsidized Federal Direct Loan program funds over refunded to the department. Context: We tested six (6) randomly selected student files totaling $7,566 Title IV funds returned to the department from a population of $106,750 Title IV funds returned to the department and found three (3) instances where the institution used the incorrect calculation resulting in funds due to the Department, and one (1) instance where the institution used the incorrect calculation resulting in too many funds returned to the department, and one (1) instance where the student received financial aid but never began attendance. Student #E2 – The student received $6,762 24-25 Unsubsidized Federal Direct Loan program funds and did not begin attendance. The institution returned $0 24-25 Unsubsidized Federal Direct Loan program funds. The institution should have returned $6,762 in 24-25 Unsubsidized Federal Direct Loan program funds. Student #E32 – The student withdrew during the Spring 2025 term and the institution returned $0 24-25 Unsubsidized Federal Direct Loan program funds. The institution should have returned $1,428 in 24-25 Unsubsidized Federal Direct Loan program funds. The institution used a start date of January 6, 2025, in the return of title IV calculation and should have used the start date of March 10, 2025, resulting in additional funds to be returned to the department in the amount of $1,428 24-25 Unsubsidized Federal Direct Loan program funds. Student #E33 - The student withdrew during the Fall 2024 term and the institution returned $1,013 24-25 Federal Pell Grant Program funds. The institution should have returned $796 in 24- 25 Federal Pell Grant Program funds. The institution’s calculation had $932 in Federal Pell Grant Program funds that could have been disbursed. The Pell funds should have been included as funds disbursed for $1,013. The institution’s calculation also used 108 total days and should have used 103 total days resulting in too many funds returned to the department in the amount of $217 24-25 Federal Pell Grant Program funds. Student #E34 - The student withdrew during the Fall 2024 term and the institution returned $0 24-25 Unsubsidized Federal Direct Loan program funds. The institution should have returned $3,179 in 24-25 Unsubsidized Federal Direct Loan program funds. The institution excluded all student financial aid disbursements from the calculation, used a start date of August 18, 2024, in the return of title IV calculation and should have used the start date of August 19, 2024, used an end date of December 12, 2024, in the return to title IV calculation and should have used the end date of December 13, 2024, resulting in additional funds to be returned to the department in the amount of $3,179 24-25 Unsubsidized Federal Direct Loan program funds. Student #E37 – The student withdrew during the Fall 2024 term and the institution returned $3,361 24-25 Federal Pell Grant Program funds. The institution should have returned $3,376 in 24-25 Federal Pell Grant Program funds. The institution used 10 days completed out of 110 days total in their return of title IV calculation and should have used 9 days completed out of 103 days total resulting in additional funds to be returned to the department in the amount of $15 24-25 Federal Pell Grant Program funds. Repeat Finding: Is a repeat finding. Recommendation: We recommend management return the funds in question and review and revise controls over student withdrawals to ensure the information used in the calculation is correct. Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations. All monies owed, will be paid back to the department. Thomas University is actively searching for a qualified individual to fill the role of Director of Financial Aid, and interview is being held with a high potential candidate on Friday June 25, 2026. Thomas University will revise and document Return of Title IV Funds procedure to ensure calculations are completed in accordance with 34 CFR 668.22 requirements. Establish standardized processes for determining withdrawal dates, enrollment status, and earned versus unearned Title IV aid. A secondary review process requiring a qualified financial aid administrator to review and approve all calculations before funds are returned or adjustments are processed. Increase coordination between Financial Aid office, Registrar Office, and Business office to endure timely communication of attendance and withdrawal information. Staff will be required to participate in periodic federal compliance training and regulatory update sessions. Planned Implementation Date of Corrective Action: December 31, 2026. Person Responsible for Corrective Action: Kurt Stringfellow, President