Finding Text
2024 – 001: Return of Title IV Funds
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date
Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement.
Questioned costs: None
Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals
Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement.
Repeat finding: Yes; prior year finding number was 2023-002.
Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.