Finding Text
Finding 2023-002
Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster
ALN: 84.268 and 84.063
Federal Award Number: P268K222290, P268K232290, P063P212290, P063P222290
Award Year: 2022-2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material
Noncompliance
Compliance Requirement: Special Tests and Provisions – Return of Title IV Funds
Criteria: Per 34 CFR 668.22(a), the University is required to have procedures in place to ensure unearned Title IV funds are correctly calculated and returned timely to the Department of Education.
For unofficial withdrawals, the University is required to determine the student’s official date of withdrawal within 30 days of the student’s last date of attendance.
According to volume 5 of the Federal Student Aid Handbook, for credit hour programs, institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance. They do not affect the calculation of the amount of Title IV aid earned. If a scheduled break occurs prior to a student’s withdrawal, all days between the last scheduled day of classes before a scheduled break and the first day classes resume are excluded from both the numerator and denominator in calculating the percentage of the term completed. If the withdrawal occurs prior to a scheduled break, the days in the break are excluded only from the denominator.
Additionally, the University is required to return unearned funds for which it is responsible as soon as possible, but no later than 45 days after the date of determination of a student’s withdrawal.
Condition: Out of a sample of 15 students who received Title IV funds and withdrew during the award year, 5 students had errors in their calculations. In the 5 student calculations, we noted one late determination of withdrawal date, three returns completed more than 45 days after the withdrawal date, two incorrect percentage of aid earned calculations, and an overpayment of $9 to the Department of Education.
Cause: Due to turnover in student financial aid department staff, individuals responsible for Return to Title IV calculations were not able to complete certain calculations timely or accurately. The review control in place did not catch the related errors.
Effect: The University may have temporarily kept funds that should have been returned to the Department of Education.
Questioned Costs: $0
Context/Sampling: A nonstatistical sample of 15 students who received $98,738 in Title IV Aid and withdrew from the University, out of a population of 73 students who received
$638,982 in Title IV aid and withdrew from the University. 5 of the students had errors in loan disbursement notification. These 5 students received $30,480 in Title IV aid (prior to the returns).
Repeat Finding from
Prior Year: No
Recommendation: We recommend the University perform refresher training with all staff assigned to perform return to Title IV calculations.
View of Responsible Officials: Management agrees with the finding. See Corrective action plan.