Finding Text
FINDING 2023-001 - Special Tests and Provisions - Return of Title IV: Significant Deficiency in Internal Control
(See III. Federal Award Findings and Questioned Costs - Finding 2023-0001 for included 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Criteria - 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume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 (1)(3) of this section.
Condition/Context-A sample of 31 students of all students who were recipients of Title IV funding and had officially or unofficially withdrawn during the period were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government's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.
For one student in the sample, Northcentral University (the University) identified the student had withdrawn and calculated the amount to be returned and submitted that amount timely. Subsequently, through a standard review process it was determined there was an error in the initial calculation of the refund. This amount was returned; however, the return was outside the 45-day period described in
34 CFR section 668.220).
Cause - The University does review Return of Title IV calculations at various points throughout the calculation and return process. However, these reviews did not identify the error in the original calculation timely.
Effect- Errors in the calculations may not be identified timely and incorrect amounts may be refunded.
Repeat Finding - This is not a repeat finding.
Recommendation-We recommend the University implement a process in which there is a timely 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 NCU Processing team has led focused R2T4 training on several subjects, including the importance of return amount inputs to ensure our R2T4 processors receive regular refresher training and coaching to prevent any R2T4 calculation inaccuracies. The Processing team will continue to conduct subject matter training monthly.
The Quality Assurance team will continue to conduct weekly R2T4 calculation reviews to demonstrate internal controls and accuracy. The Quality Assurance review process includes reviewing the R2T4 calculation for accuracy and verifying that all system inputs such as EDExpress and COD are completed correctly.