Finding Text
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: 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. Per 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.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.