Finding Text
2024-002 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)
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 completed days in the payment period or period of enrollment in calculating the percentage of the
Title IV aid earned.
Questioned Costs: This finding is monetary in nature. In the instances noted in testing, the total error
identified is $1,992 in over-award. Extrapolation of this monetary error was not necessary as the 5
withdrawal students tested as part of the 2024 audit constitute the entire withdrawal population for
the period under audit. This does not exceed the $25,000 reporting threshold for monetary error
within Federal Award Programs.
Perspective Information: The audit included a detailed testing of 5 withdrawal student files, of which
this significant deficiency applies to 1, indicating an error rate of 20.0%. This does exceed the reporting
threshold of 10% for Federal Award Programs.
Cause and Effect: For one withdrawal calculation performed, the day count for days completed by
the student was not performed per the instructions described in the Student Financial Aid Handbook.
The student identified was enrolled in multiple modules within the same term. The individual
withdrew from all classes enrolled in the earlier module, returned at the start of the second module,
and then withdrew from the latter module and therefore, the University. At this time, an R2T4 was
completed and in calculating completed days for the student, the University did not reduce the
calculation of calendar days completed for the break between the withdrawal from the first module
and the beginning of the second module. The use of an incorrect number of completed calendar days
results in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary
error.
Recommendation: The University should ensure that the number of completed days in the payment
period or period of enrollment are counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: The University has determined that this matter constitutes a unique
training situation involving the application of procedures related to the Return of Title IV funds. In
particular, the University recognizes the need for enhanced training concerning the accurate counting
of days when a student withdraws, provides written notification of their intent to attend a future
module within the same term, and subsequently withdraws from that second module. The error in
question arose from the miscalculation of days, where the University inadvertently counted all days
in the initial module rather than counting only the days leading up to the student's initial withdrawal
prior to the final withdrawal from the second module. This oversight was attributed to an individual
employee, and the University has proactively implemented comprehensive training and procedural
safeguards to prevent similar occurrences in the future.