Finding Text
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section. Institutions required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution?s determination that the student withdrew should be no later than 14 days after the student?s last date of attendance as determined by the institution from its attendance records. 34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) 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. Condition/context ? A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause ? The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Effect ? If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government. Repeat finding ? This is a repeat finding, see 2021-001. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. We also recommend NU implement a process in which there is a final review of the Title IV return after the fact to ensure all steps are performed timely. Views of responsible officials and planned corrective actions ? NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.