Finding Text
2024-004 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 2023-005)
Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance
earned should be applied to the total amount of title IV grant or loan assistance that was disbursed
or could have been disbursed to the student, or on the student's behalf, for the payment period or
period of enrollment as of the student's withdrawal date.
Statement of Condition: During the audit, it was noted that the University used the incorrect sum
of aid disbursed or disbursable to the student when applying the percentage earned in calculating
the return to Title IV Funds upon student withdrawal.
Questioned Costs: The known monetary error is $1,984 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which this issue could have affected exist beyond those tested during the audit, as all withdrawn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 incorrect sum of disbursed or disbursable
aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This
results in a miscalculation of Title IV aid earned and could result in monetary error.
Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the
University should ensure that the calculated percentage of Title IV earned is applied to the total
assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the
guidance provided by the Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University has enhanced the process of completing return to Title
IV calculations by incorporating additional training and workshops provided by the Department of
Education. The financial aid office has continued with the implementation of the calendar that
displays the attendance days from the first day of school to the last day of school, referring to the
school’s master calendar. The financial aid office added an extra verification step of written
notification from the Registrar’s office of beginning and end days for each semester. The return
calculations were one day off due to the misinterpretation of the semester’s ending date.