Finding Text
Criteria
According to 34 CFR 668.22(f)(2):
(i) The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
(ii) The total number of calendar days in a payment period or period of enrollment does not include –
(A) Days in which the student was on an approved leave of absence; or
(B) For a payment period or period of enrollment in which any courses in the program are offered in modules, any scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time.
Condition
The Federal Government requires that when the student withdraws from all classes, the College calculate the student’s percentage of Title IV aid earned. This is calculated by dividing the number of days the student attended classes by the total number of days in the academic period. The total number of days in the academic period (semester) includes all calendar days between the start and end of academic activities. During our testing, we noted 5 students, out of a sample of 6, where the incorrect number of total days in the Fall and Spring semester were used to calculate the students’ percentage of Title IV earned.
Cause
The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. In this instance, the College incorrectly calculated the enrollment period because the College’s calculation excluded the last day in which classes were held in its calculation of period of enrollment.
Effect
The College calculated the Return to Title IV (“R2T4”) forms incorrectly and returned an excess amount of Title IV funds to the Department of Education.
Questioned Costs
$23
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 6 students selected for testing, 5 students, or 83.33% of our sample, had refunds that were calculated using an incorrect number of total days in the payment period.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should provide training to employees responsible for completing the Return of Title IV calculations and ensure that they have adequate knowledge in the related rules and regulations. The College needs to implement a formal review process of the Return of Title IV calculations by an individual with proper knowledge of the federal regulations.
View of Responsible Officials
The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.