Finding 505511 (2024-001)

FINDING 2024-001 – Special Tests and Provisions-Return of Title IV Funds – Significant Deficiency In Internal Controls Over Compliance. Criteria: When a recipient of Title IV loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. The regulations (34 CFR 668.22(f)(2)) provide that the total number of calendar days in a payment period or period of enrollment include all days within the period that the student was scheduled to complete and the number of calendar days completed in the period, except that scheduled breaks of at least five consecutive days and days on which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period or period of enrollment. The regulations (34 CFR 668.22(e)(4)) provide the total amount of unearned Title IV grant or loan assistance that has not been earned by the student and therefore is calculated by determining the complement of the percentage of Title IV grant or loan assistance earned by the student as described in 34 CFR 668.22(e)(2). The regulations do not prohibit a school from developing its own refund policy however, the school must comply with refund policies required by the noted regulations. Although the refund policy of the school will determine the charges a student will owe after withdrawing, those policies will not affect the amount of Title IV aid the student has earned under the R2T4 calculation. Condition/context: We selected a sample of five students out of a population of 21 that were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. We believe this to be a representative sample of the population and a statistical sample. We found two calculations of the return of Title IV funds contained errors related to the total number of days in the term because consideration for the exclusion of certain days from the winter scheduled break were not properly implemented. This calculation error caused two of the five samples to have the wrong total of aid earned because those two students had withdrawn before the 60% completion threshold. In this same sample universe, two students had incorrect calculations of values to be returned because the institutional charges were not included in the R2T4 calculation. In both cases, the students began a term while the school evaluated their academic performance from the previous term. The students were dismissed from their respective programs based on academic performance, but the school refunded full tuition and fees as the students were not given adequate opportunity to attend the terms for which they withdrew. As such, the school had considered the full tuition refund as a $0 institutional charge on the R2T4 calculation which caused calculation errors for what was earned in the term. These two errors caused an understatement of $24,127 unsubsidized loan that would be required to be returned by the school. Questioned costs: No questioned costs were identified as part of this finding. Cause: In discussing these conditions with the University’s management, the department had input the start dates of the scheduled winter break as the first Monday after scheduled instruction, rather than the day after the final day of scheduled instruction time, which erroneously removed weekend days from the calculation. Effect: The overstated total days in term caused the calculation of aid earned to be understated and therefore more federal funding was returned than a proper calculation would have concluded. Repeat finding: This is not a repeat finding. Recommendation: We recommend the University update their policies and procedures to calculate the return of Title IV funding accordingly to ensure accurate calculations are performed. Views of responsible officials: Management agrees with the finding. A corrective action plan has been created by management and is included in the following section.