Finding Text
Student Financial Assistance Cluster
Federal Supplemental Educational Opportunity Grants, ALN 84.007;
Federal Work-Study Program, ALN 84.033
Federal Pell Grant Program, ALN 84.063
Federal Direct Student Loans, ALN 84.268
Teacher Education Assistance for College and Higher Education Grants, ALN 84.379
U.S. Department of Education
Program Year 2023-2024
Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5)
Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely.
Questioned costs - $0
Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements.
Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal.
Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely.
Identification as a repeat finding, if applicable – 2023-001 and 2022-001
Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely.
Views of responsible officials and planned corrective actions –
With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows:
1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding.
Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024.
2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation.
1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office.
2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024.
3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency.
Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.