Finding Text
Finding 2023-003: Significant Deficiency – Return of Title IV Funds
Program: Federal Direct Student Loans
Assistance Listing Number: 84.268
Federal Agency: U.S. Department of Education
Federal Award Identification Number: P268K233683
Federal Award Year: June 30, 2023
Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance
withdraws from an institution during a payment period or period of enrollment in which the
recipient began attendance, the institution must determine the amount of Title IV grant or loan
assistance that the student earned as of the student's withdrawal date in accordance with Federal
regulations and return the unearned portion of the grant or loan funds to the Title IV programs as
soon as possible but no later than 45 days after the withdrawal date.
Condition/Context: In a sample of 14 students that withdrew during the fiscal year, the University
did not perform the required return to Title IV calculations for two students who completed less
than 60% of the payment period. The sample was not a statistically valid sample.
Cause: The University incorrectly interpreted the period of enrollment to be the one module and
not the entire payment period for the withdrawal exemption for successful completion of 49% or
more.
Effect: The University incorrectly calculated students as having completed less than 60% and
therefore did not perform R2T4 calculations or return unearned loan funds to the Department.
Additionally, some R2T4 calculations were incorrect based on the calculation using only the
module not the days in the payment period.
Questioned costs: Total questioned costs were $3,060 of Direct Student Loan funds.
Recommendation: It is recommended that the University review interpretations, policies and
procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and
institutional charges are being used.