Finding Text
2024-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D.
Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal
Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379)
(Repeat Finding 2022-003 and 2023-004)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect
number of total days in the payment period or period of enrollment in calculating the percentage of
payment period and/or period of enrollment completed.
Questioned Costs: The known monetary error is $20 under-awarded. Extrapolation of the error was
not necessary because all withdrawals were tested during the audit. Therefore, the monetary
impact of this deficiency does not exceed the reporting threshold of $25,000.
Perspective Information: The audit included a detailed testing of 2 student files, of which this
significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to
which this issue could have affected exist beyond those tested during the audit, as all withdrawn
students were examined.
Cause and Effect: For noted withdrawal calculations, the total day count was not performed per
the instructions described in the handbook. This results in a miscalculation of percentage of Title IV
aid earned and could result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment is counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University improved the process for completing return to Title IV
calculations by adding in additional training and workshops offered through the Department of
Education. The financial aid office continued with the calendar process showing days of attendance
from the first day of school to the last using the school’s master calendar as a reference. This will be
used also as a double check of days when calculating returns. The dates used in the return
calculations were off a day due to misreading the ending date of semester. The Financial Aid
Administrator verified the beginning and last day of each semester with the Registrar’s office in
writing.