Finding Text
2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 6 student files, of which this
significant deficiency applies to 2, indicating an error rate of 33.30%.
Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office created a calendar showing days of attendance from the first day
of school to the last using the school’s master calendar as a reference. This will be used also as a
double check of days when calculating returns. The dates used in the return calculations were off a
day due to misreading the ending date of semester.