Finding Text
Criteria or specific requirement - Special Tests and Provisions – Return of Title IV Funds
(34 CFR 668.22(a)(1) through (a)(5)
Condition - The University’s internal controls did not ensure the returns of Title IV funding
were calculated correctly and resulted in improper and missing returns.
Cause – The University did not calculate total days payment periods correctly for all
students. The University did not properly account for breaks in semesters.
Effect or potential effect – The University returned the incorrect amount of funds, did not
return funds, did not return funds timely, and did not return funds in the incorrect order
Questioned costs – ALN 84.063 - $1,166; ALN 84.268 - $935; Total $2,101. Calculated
using amounts under-returned to the Department of Education.
Context – Out of the population of 205 students who withdrew, 22 were selected for
testing. Our sampling method was not, and was not intended to be statistically valid.
Total days in the semester were calculated incorrectly.
Identification as a repeat finding, if applicable – Not applicable
Recommendation – The University should update their controls to ensure total days in
the semester are calculated correctly, funds are returned in the correct order and postwithdrawal
disbursements are made correctly
Views of responsible officials and planned corrective actions – Management
acknowledges an error in calculating the total number of days in the semester for
Return of Title IV funding calculations. The semester days have been corrected, and
going forward, they will be thoroughly verified against the academic calendar to ensure
accuracy. Additionally, the University has updated its process for managing Return of
Title IV calculations. The revised process includes an individual review of each
student’s enrollment to ensure that any breaks in enrollment are accurately accounted
for. As a part of these improvements, the University will implement a double verification
process during the annual setup to ensure all data is used for calculations is accurate
and consistent