Finding Text
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN:
84.007), Federal Pell Grant Program (ALN: 84.063), Federal
Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement
(Including Statutory, Regulatory or
Other Citation):
N. Special Tests and Provisions – Return of Title IV Funds: The
amount of earned Title IV grant or loan assistance is
calculated by determining the percentage of Title IV grant or
loan assistance that has been earned by the student and
applying that percentage to the total amount of Title IV grant
or loan assistance that was or could have been disbursed to
the student for the payment period or period of enrollment
as of the student’s withdrawal date. A student earns 100
percent if his or her withdrawal date is after the completion
of 60 percent of (1) the calendar days in the payment period
or period of enrollment for a program measured in credit
hours, or (2) the clock hours scheduled to be completed for
the payment period or period of enrollment for a program
measured in clock hours (34 CFR 668.22(e)(2)). Otherwise,
the percentage earned by the student is equal to the
percentage (60 percent or less) of the payment period or
period of enrollment that was completed as of the student’s
withdrawal date. The percentage of Title IV grant or loan
assistance that has not been earned by the student is the
complement of one of these calculations. Standard termbased
institutions must always use the payment period as the
basis for the determination.
The unearned amount of Title IV assistance to be returned is
calculated by subtracting the amount of Title IV assistance
earned by the student from the amount of Title IV aid that
was disbursed to the student as of the date of the institution’s
determination that the student withdrew (34 CFR 668.22(e)).
Condition:
The University did not properly calculate the amounts to be
returned to the ED. Additionally, the University was unable
to provide evidence of approval from the borrower prior to
making a post-withdrawal disbursement of loan funds.
Cause: Administrative oversight and lack of sufficient internal
controls with respect to return of Title IV fund calculations
and post-withdrawal disbursements.
Effect: The University was not in compliance with the return of Title
IV funds requirements.
Questioned Costs: Sampled questioned costs: $12,572; total questioned costs:
indeterminable.
Context: For 3 of 5 students selected for testing, the University did not
properly calculate the amount of Title IV aid to be returned
to the ED. Additionally, funds due for return were either not
returned or were not returned timely for 3 of 5 students.
For 1 of 5 students selected for testing, the University did not
retain documentation of the student’s or parent’s approval
obtained prior to making a post-withdrawal disbursement of
loan funds.
Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as
Finding 2022-005 in the prior year schedule of findings and
questioned costs.
Recommendation: We recommend the University enhance its procedures and
internal controls over the return of Title IV fund calculations
to ensure that returns of funds are calculated accurately, and
that adequate records are maintained to support proper
procedures for post-withdrawal disbursements.
Views of Responsible Officials and
Planned Corrective Actions:
The Financial Aid office made several staffing changes in
2022-2023. The newly hired staff did not receive the proper
training to perform their roles effectively. This led to errors
identifying and calculating the unearned amount of Title IV
assistance to be returned. The previous Financial Aid Director
was terminated before the prior corrective action plan could
be fully completed. New leadership, in collaboration with the
Office of Information Technology, has developed an
automated weekly report confirming student withdrawal
dates. The report is scheduled to be emailed to Financial Aid
office every Friday. The Financial Aid Director reviews the
report and identifies Title IV recipients. The return of title IV
funds calculation would be performed for those students. Any
funds required to be disbursed or returned would then be
processed.