Finding Text
Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts
be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A
student or parent may authorize the Institution to hold the credit balance to be applied to specified other
nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the
regulations at (34 CFR 668.165(b)).
Condition/Context: For 4 of 25 students tested, the students’ Title IV credit balances on their accounts
were held and applied to future charges without student or parent authorization.
The sample was not a statistically valid sample.
Cause: The University's controls surrounding Title IV credit balances being paid timely or being held only
when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances.
Effect: Title IV credit balances were held without student/parent authorization and applied to future charges.
Questioned Costs: Total questioned costs were $18,947 of Federal Direct Student Loan funds ALN
84.268.
Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid
timely or student/parent authorizations to hold funds are obtained.
Management's Response: The University agrees with the finding. The occurrence of Title IV credit
balances occurs primarily with graduate program students. A review is being conducted of current internal
control processes and evaluating what additional reporting is capable within the student information system
to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are
being monitored during the Spring 2023 terms and new procedures will be put in place for the Fall 2024
term.