Finding Text
Untimely Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants, 84.268 Federal Direct Student Loans Federal Award Identification #: 2025-2026 Financial Aid Year Condition: When students withdrew officially or unofficially during a term, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $15,522 Context: Out of 40 students tested, 2 students who withdrew during the audit period tested did not have unearned Title IV funds originally returned. 1 student had $1,578 in Federal Direct Loans returned in June 2026, 164 days late. 1 student had $3,476 in Pell returned in July 2026, 109 days late. These amounts are included in the questioned costs. As part of a full file review, the University identified 10 additional students who did not meet the 60% attendance mark yet did not have R2T4s performed. All of these were corrected and resulted in $7,389 of Federal Loans and $3,079 of Pell returned in September 2026 as part of the audit process, ranging from 200 to 279 days late, and are therefore included as questioned costs. Cause: This was an oversight by the University resulting from a lack of reliable last date of participation data in the student systems. Until this issue is resolved, the University will be manually reviewing all 0-credit students at the end of each term. Effect: Incorrect amount of unearned Title IV funds returned, returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review modular students R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.