Finding Text
Criteria: 34 CFR 668.22(j)(1) requires the University to 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 University’s determination
that the student withdrew.
Condition: The University did not return all Title IV funds in a timely manner.
Context: We selected a non-statistical sample of 8 students out of a population of 68 students who withdrew
during the year and had Title IV funds disbursed. We noted 6 out of 8 students required a return of Title
IV funds and for 5 out of the 6 students, the University did not return funds to the Department of Education
within the required time frame.
Cause: Although the University has policies and procedures in place over the return of Title IV funds,
management indicated that staff turnover, including the resignation of the Director of Financial Aid,
resulted in the remaining staff being required to take on additional responsibilities to ensure the continuity
of day-to-day functions of the office. In addition, the changes required by the FAFSA simplification act
caused the team to be unable to timely comply with the existing policies.
Effect: Failure to timely return Title IV funds resulted in noncompliance with the special tests and
provisions – return of Title IV funds requirement.
Questioned Costs: None
Identification of a repeat finding: N/A
Recommendations: We recommend the University be more diligent in complying with its established
policies and procedures for the return of Title IV funds. Where staffing shortages exist, consider crosstraining
staff or temporarily engaging external resources.
Views of responsible officials: This issue was initially identified by the University through HPU’s internal
monitoring processes. The cause was significant staff turnover within a 6-month period (including the
resignation of the Director of Financial Aid). The difficulties of temporarily reduced staffing and loss of
institutional knowledge were compounded by the challenges brought by the FAFSA Simplification Act,
which required many changes, placing an additional burden on a strained team. Although the University
attempted to adhere to its policies and procedures to ensure that R2T4 is processed within the allotted time,
the team did not succeed in completing this function. The University replaced key staff, recruited a new
Director, and shifted responsibilities so that a specific staff member is responsible for R2T4 processing.
These changes have enabled the University to resume processingR2T4 timely, as was accomplished in
previous years.