Finding Text
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, &
P033A221190-2023
Award Period: July 1, 2022 to June 30, 2023
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations.
Questioned costs: None
Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions.
Cause: The College was using the incorrect number of scheduled break days for Spring Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: No
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.