Finding Text
Information on the Federal Program – Department of Education,
Student Financial Assistance Cluster, Federal Supplemental
Educational Opportunity Grant Program, CFDA 84.007; Federal
Work-Study Program, CFDA 84.033; Federal Pell Grant
Program, CFDA 84.063; Federal Direct Student Loan Program,
CFDA 84.268.
Program Year – July 1, 2023 – June 30, 2024
Criteria for Specific Requirement – Special Tests and
Provisions – Return of Title IV Funds – Return of Title IV
funds are required to be deposited or transferred into the SFA
account or electronic fund transfers initiated to ED as soon as
possible, but no later than 45 days after the date the institution
determines that the student withdrew. Returns by check are late
if the check is issued more than 45 days after the institution
determined the student withdrew or the date on the canceled
check shows the check was endorsed more than 60 days after
the date the institution determined that the student withdrew (34
CFR 668.173(b)).
Condition – Return of Title IV funds from the College was not
initiated to ED within the required timeframe.
Questioned Costs – None – nonmonetary finding
Context – Out of a sample of 4 students from a population of 18
students who were required to have a Return of Title IV Funds
calculation performed during the year, the College did not initiate
the Return of Title IV funds to ED within the required timeframe
for one student. Our sample was not, and was not intended to
be, statistically valid.
Cause – Return of Title IV funds was not initiated to ED timely.
This could have been a result of limited communication between
those with direct knowledge of student withdrawals and those
responsible for calculating and initiating the Return of Title IV
funds.
Effect – Return of Title IV funds was ultimately returned to ED but
was not initiated timely
Identification as a Repeat Finding – N/A
Recommendation – We recommend the College ensure there is
consistent communication between those with direct knowledge
of student withdrawals and those responsible for calculating and
initiating the Return of Title IV funds.
Views of Responsible Officials and Planned Corrective
Actions – The College has established a policy of governing the
Return of Title IV funds for its students in prison. The policy
better defines withdrawals for this unique student population,
and institutes regular meetings at critical dates throughout the
semester between the Director of the Moreau College prison
initiative, the Registrar, Finance, the Office of Financial Aid, and
the Vice President for Enrollment and Student Engagement to
ensure student withdrawals from both the prison program as well
as the residential campus are known and recorded, and the
Return of Title IV funds process can be completed within the
required timeframe. Additionally, the College continues to invest
in its Office of Financial Aid through hiring of additional support
and enrolling its senior administrators in the NASFAA Certified
Financial Aid Administrator Program.