Finding Text
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). 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 aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.