FINDING 2022 – 006:
Type of Finding: Significant Deficiency-Return of Title IV Funds
Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid
Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of
grants or loans to the student based the calculated percent completed by the student.
Condition: Calculations of return of funds for certain students selected for testing were not completed
and therefore refunds were not made.
Corrective Action: Audit results identify several Wheeling University Financial Aid R2T4 calculations that
were found to be incomplete, inaccurate, or not completed within an acceptable time frame as required
by regulations. The apparent cause of these findings was a lack of administrative capability, staff
turnover, and a general lack of a systematic process for completing accurate R2T4 calculations. Since
these findings were first noted, the Wheeling University Financial Aid Office has added competent staff
and has provided sufficient training and supervised experience to ensure R2T4 calculations are
completed within the regulatory guidelines. The acting Director of Financial Aid has taken steps to
ensure to inform the campus community of the Department’s philosophy of an “institutional
responsibility” regarding regulatory compliance with Title IV programs, and this is particularly true in the
matter of student FA eligibility with enrollment, attendance, and withdrawal. As such, the acting
Director of Financial Aid has worked closely with the University Registrar to ensure there is a clear
understanding that if a recipient of Title IV grant or loan funds withdraws from the University after
beginning attendance, the FA Office must perform an R2T4 calculation to determine the amount of Title
IV assistance earned by the student. Since withdrawal information is critical to R2T4 calculations, a
Withdrawal Report has been developed to better capture withdrawal data. This report is updated and
reviewed by the FA Director (three times per week) to confirm the accuracy of such data. In addition, all
R2T4 calculations are completed on the University's internal software (Colleague) rather than DOE
software and follow an updated, more clearly defined R2T4 policy.
Anticipated Completion Date: This process was completed September of 2023 and is ongoing.