Finding 513901 (2024-001)

Return of Title IV Funds for Failure to Begin Attendance DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not always return Title IV aid timely when a student failed to begin attendance as evidenced by academic engagement. Criteria: 34 CFR 668.21 Questioned Costs: $5,071 Context: Out of 19 students tested for timely Return to Title IV, there was 1 student identified who did not begin attendance based on their online academic activity. This resulted in questioned costs of $5,071 in unsubsidized federal direct loans that should have been returned to Department of Education within 30 days of the term’s start. This was corrected during the audit. Cause: The University did not properly review students with zero credits who received Title IV aid to determine if students had academic activity to establish attendance. Effect: Title IV funds were not returned timely. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University reviews online academic activity, in addition to the professor’s evaluation, to confirm the last date of attendance for the student to be able to properly evaluate if an R2T4 is required. The University should also have procedures in place to determine if students actually begin attendance in each class of the term for which they receive Title IV aid. If the last date of attendance cannot be identified, the University should default to the midpoint of the term for the R2T4, in line with the University’s policy and non-attendance taking regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.