FAC Explorer

Finding 2267 (2023-004)

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Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-11-21
Audit: 3911
Organization: Vermont State Colleges (VT)
Auditor: Withumsmith+brown PC

AI Summary

  • Core Issue: The Colleges failed to return unearned Title IV funds within the required 45-day timeframe after student withdrawals.
  • Impacted Requirements: Compliance with 34 CFR 668.22(j)(1) and 34 CFR 668.173(b) regarding timely returns of Title IV funds.
  • Recommended Follow-Up: Strengthen monitoring and controls to ensure all unearned Title IV funds are returned on time to the Department of Education.

Finding Text

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $26.17M
84.063 Federal Pell Grant Program $13.10M
84.042 Trio_student Support Services $1.50M
84.047 Trio_upward Bound $1.31M
93.575 Child Care and Development Block Grant $1.30M
84.033 Federal Work-Study Program $1.27M
59.077 Community Navigator Pilot Program $1.16M
84.007 Federal Supplemental Educational Opportunity Grants $1.11M
59.037 Small Business Development Centers $1.01M
90.601 Northern Border Regional Development $810,690
84.031 Higher Education_institutional Aid $797,633
84.116 Fund for the Improvement of Postsecondary Education $333,171
84.425 Education Stabilization Fund $329,611
94.006 Americorps $308,447
84.048 Career and Technical Education -- Basic Grants to States $292,268
84.217 Trio_mcnair Post-Baccalaureate Achievement $246,016
21.027 Coronavirus State and Local Fiscal Recovery Funds $238,154
16.753 Congressionally Recommended Awards $224,446
93.236 Grants to States to Support Oral Health Workforce Activities $210,251
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $175,896
17.285 Apprenticeship USA Grants $169,186
93.859 Biomedical Research and Research Training $150,474
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $146,104
47.073 National Science Foundation/uvm/ns $123,509
93.959 Block Grants for Prevention and Treatment of Substance Abuse $90,548
93.778 Medical Assistance Program $77,868
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $75,721
11.611 Manufacturing Extension Partnership $67,504
93.958 Block Grants for Community Mental Health Services $64,295
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $62,000
59.059 Congressional Community Project $58,847
47.050 Geosciences $52,669
20.205 Highway Planning and Construction $48,093
93.855 Allergy, Immunology and Transplantation Research $47,906
11.307 Economic Adjustment Assistance $41,778
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $38,305
84.181 Special Education-Grants for Infants and Families $33,910
10.575 Farm to School Grant Program $20,408
17.720 Disability Employment Policy Development $19,364
10.500 Cooperative Extension Service $17,899
43.001 Science $7,008
93.434 Every Student Succeeds Act/preschool Development Grants $7,000
45.025 Promotion of the Arts_partnership Agreements $3,122
11.467 Meteorologic and Hydrologic Modernization Development $1,066
93.888 Specially Selected Health Projects $944