Finding 1939 (2023-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-11-15

AI Summary

  • Core Issue: The University failed to return unearned Title IV funds on time after student withdrawals, missing the 45-day deadline.
  • Impacted Requirements: This violates 34 CFR 668.22, which mandates timely returns of Title IV aid.
  • Recommended Follow-Up: Implement regular reviews of withdrawal lists and R2T4 calculations, and assign an experienced staff member to oversee compliance.

Finding Text

Untimely Return of Title IV (R2T4) Funds Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely within the 45 days from the determination of the student’s withdrawal. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 9 withdrawals tested (both official and unofficial), 2 students who withdrew in Fall 22 had funds totaling $9,484 returned in September 2023, 189 days late. 1 other student had a corrected R2T4 calculation completed in Fall 22 based on an updated last date of attendance resulting in $1,776 funds owed to the student but it wasn’t disbursed until September 2023. Cause: Lack of review over individual R2T4 calculations, particularly unofficial withdrawals Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Yes, 2022-001 Recommendation: We recommend that the University run a listing of withdrawals after each semester and compare the list of students who had R2T4’s completed to ensure completeness. We further recommend a 0-credit report be run at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. We also recommend an individual in financial aid with the appropriate level of experience periodically review 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.

Corrective Action Plan

Return of Title IV (R2T4) Errors Planned Corrective Action: Our process for identifying unofficial withdrawals begins with a report from our Workday software to identify students who had unearned credits in a semester at the conclusion of that semester, after the grade due date. We then reach out to the individual professors of the courses and/or the Instructional Design team to determine if each student completed the semester or if (s)he had unearned credits having ceased attending at some point during the semester. If the student ceased attending, we would determine if a Return of Title IV (R2T4) calculation was needed and would complete it if necessary. The report was corrected for AY 2022/2023 to include No Credit (NC), Incomplete (I) and Failed (F) grades to enable PLNU to identify all the students who need to be reviewed going forward. In addition, we have added to our process instructions to run this report after the grades for module 1 are due, and after the grades for module 2 are due, rather than at the end of each semester. This was intended to ensure the review of any unofficial withdrawals in a timelier manner, meeting the 45-day deadline for any possible returns that must be made. The modified report, however, produced a far greater number of students for review, which was too broad of a selection and was unmanageable. We are working to refine the reporting criteria further to accurately identify students who require review and we have assigned additional staff for the review process. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid; Joanna Castro, Associate Director of Financial Aid; Jamie Asche, Director of Student Financial Services Business Analysis and Compliance Anticipated Date of Completion: 1/1/2024

Categories

Internal Control / Segregation of Duties Student Financial Aid Reporting Significant Deficiency

Other Findings in this Audit

  • 1940 2023-001
    Significant Deficiency Repeat
  • 578381 2023-001
    Significant Deficiency Repeat
  • 578382 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $36.87M
84.063 Federal Pell Grant Program $3.70M
84.038 Federal Perkins Loan Program $1.45M
84.033 Federal Work-Study Program $579,056
93.264 Nurse Faculty Loan Program (nflp) $407,220
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $348,651
84.007 Federal Supplemental Educational Opportunity Grants $299,416
93.364 Nursing Student Loans $190,163
84.408 Postsecondary Education Scholarships for Veteran's Dependents $6,501