Finding Text
Criteria or Specific Requirements
34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer 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 cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew.
OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period.
Condition
Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance:
- For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement.
- For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds.
Cause
The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements.
Effect
The District is not in compliance with the aforementioned criteria.
Questioned Costs
There are no questioned costs associated with this finding.
Context
The District performed 541 Return to Title IV calculations during the year ended June 30, 2024.
Repeat Finding (Yes or No)
No.
Recommendation
The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.