Finding Text
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.