Finding Text
Finding No. 2022?001 ? Special Tests and Provisions ? Return of Title IV Funds Federal Program ALN 84.063, Federal Pell Grant Program (PELL), Student Financial Assistance Programs Name of Federal Agency U.S. Department of Education (USDE) Category Internal Control/Compliance Compliance Requirement Special Tests and Provisions Criteria 34 CFR Section 668.173 (b) states that 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 ?668.163 no later than forty-five (45) days after the date it determines that the student withdrew; (2) the institution initiates an electronic fund transfer (EFT) no later than forty five (45) days after the date it determines that the student withdrew; (3) the institution initiates an electronic transaction, no later than forty five (45) days after the date it determines that the student withdrew, that informs a Federal Family Education Loan (FFEL) lender to adjust the borrower's loan account for the amount returned; or (4) the institution issues a check no later than forty-five (45) days after the date it determines that the student withdrew. Universidad Central de Bayamon, Inc. Condition The return of Title IV funds as calculated by the University was performed after the required 45 days, in the following case: Finding Number Student Identifier OPEID Pell Disbursed ($) Pell Under- Payment ($) Pell Over- Payment ($) Direct Loan Disbursed ($) Direct Loan Under- Payment ($) Direct Loan Over- Payment ($) 2022-001 Student 1 502200 $ 2,436 * $ - $ - $ - $ - $ - * There was no under-payment or over-payment of Title IV funds. Cause In this case, the disbursement of Title IV funds was processed at the same date and time of the R2T4. This action caused the process of R2T4 to be interrupted and the personnel become aware of the issue several days later. Effect As a result of these conditions, the U.S. Department of Education may impose penalties to the University or issue a warning as to incur in a probation status. It also could deprive other needy students of federal funds. Context Of the 116 cases of withdrawal, we examined forty (40) participants and determined that in one (1) case the Return of Title IV funds was performed late. The composition of the audit samples for the Pell grant and direct loans programs and the population from which the samples were drawn were as follows: i. Pell Grant Program: Sample Description Related Compliance Requirement OPEID Student Receiving Pell (#) Pell Disbursed ($) Students Receiving Pell (#) Pell Disbursed ($) Elegibility Sample Eligibility; and, Special Tests and Provisions - Verification and Disbursements to or on Behalf of Student 00502200 36 $ 194,814 728 $ 3,575,369 Return of Title IV Funds Sample Special Tests and Provisions - Return of Title IV Funds 00502200 29 $ 74,690 75 $ 205,924 Sample and Population Overlap 2 $ 74,690 75 $ 205,924 Population from which the Sample Sample was drawn ii. Direct Loans Program: Sample Description Related Compliance Requirement OPEID Student Receiving Direct Loans (#) Direct Loans Disbursed ($) Students Receiving Direct Loans (#) Direct Loans Disbursed ($) Elegibility Sample Eligibility; and, Special Test and Provisions - Verification and Disbursement to or on Behalf of Student 00502200 5 $ 30,250 370 $ 1,751,670 Return of Title IV Funds Sample Special Test and Provisions - Return of Title IV Funds 00502200 14 $ 48,370 11 $ 32,086 Sample and Population Overlap - $ - 11 $ 32,086 Population from which the Sample Sample was drawn Identification of a repeat finding No Questioned costs None Recommendation The University management should reinforce its procedures to ensure that disbursement of Title IV funds and R2T4 process are running separately and that each process be revise to make sure it was completed. Also, management should continue to improve its processes including the communications between departments to ensure that return of Title IV funds is made within the prescribed period of time. Views of responsible officials and planned corrective actions The University management agrees with this finding. Please refer to the corrective action plan on page 52.