Finding 518427 (2024-002)

Special Tests and Provisions – Return of Title IV Funds Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Grant Program U.S. Department of Education (ED) Program Year 2023-2024 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Management is responsible for compliance with Special Tests and Provisions – Return of Title IV Funds procedures in accordance with the Uniform Guidance. (34 CFR 668.22) Condition: Federal regulations provide that the University is responsible for returning funds to ED and student accounts within 45 days of the University becoming aware the student has withdrawn, or within 30 days for students that never began attendance. The University’s internal control system did not prevent a late disbursement of return of funds. Questioned Costs: None Context: Out of a population of 78 withdrawn students requiring return of Title IV funds, a sample of eight withdrawn students were selected for testing. One out of the eight returns were not returned to ED or the student within the 45-day period. Our sampling method was not, and was not intended to be statically valid. Effect: The University may not be able to timely detect when return of funds are required for students who withdrew. This could result in late disbursements to ED and the student accounts for Direct Loan and Pell recipients. Cause: The University’s processes did not ensure return of Title IV funds were completed timely. Repeat Finding: No Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to properly capture return of Title IV funds on a timely basis. Views of Responsible Officials: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.