Finding Text
FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Significant Deficiency in Internal Control - See Schedule of Findings and Questioned Costs for chart/table. - Criteria ? 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume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 withdraws. 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 A sample of 40 students who were recipients of Title IV funding and had officially or unofficially withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s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. Northcentral University (NCU) did not identify 3 students as withdrawn within the required timeframe. Additionally, for 4 for of the 40 sample students, the amount to be returned was not returned within the required 45 days after the date of NCU?s determination of withdrawal. Cause ? NCU does review Return of Title IV calculations at various points throughout the calculation and return process. However, these reviews did not timely identify funds required for return. Additionally, the attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify all students whom had stopped attending class prior to completion of a payment period. Effect ? Students whom stopped attending class prior to the completion of a payment period were not timely identified as withdrawn. Although eventually returned, funds required to be returned were not returned timely. Repeat Finding ? This is not a repeat finding. Recommendation ? We recommend NCU revise their system queries to capture all withdrawn students and implement a process by which the queries are tested annually. We also recommend NCU implement a process in which there is a final review of the Title IV return after the fact for all students to ensure all aspects are correct and timely. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the importance of ensuring that the return of Title IV funds (R2T4) are performed both timely and accurately. The University has instituted a new workflow process that is easily tracked and reported, allowing our team to monitor and control the R2T4 process more effectively. In addition, the quality assurance team at NCU is now performing regular and periodic file reviews to ensure file accuracy. The quality assurance process includes a review of both an assessment of the accuracy of our calculations and that all required R2T4s are complete. These new internal controls ensure we process R2T4 in accordance with 34 CFR section 668.22 (2)(i) in the required timeframe. We anticipate the changes mentioned above will remediate this repeat finding.