Finding Text
Finding 2024-003: Return of Title IV Funds - Significant Deficiency
Repeat Finding: 2023-003
ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the
student earned as of the student's withdrawal date in accordance with Federal regulations and return
the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no
later than 45 days after the withdrawal date.
Condition: For one student selected for testing, the return of Title IV funding was not returned within
45 days of the date that it was determined that the student withdrew. For one student tested, the
semester parameters utilized by the College were inaccurate. The College originally determined that
the student had completed less than 60% of the semester and a refund was required. However, a
return was not required based on the student's actual semester length.
Cause: The College had turnover in staffing within the financial aid department causing these
procedures to be missed.
Effect: The amounts refunded to the Department of Education may be incorrect. The College was
also in possession of funds belonging to the federal government longer than allowed.
Questioned Costs: $1,967
Context: There were a total of 19 students who withdrew during the year that received Title IV aid.
There was only one student that the College determined to require a return of Title IV funds. There
was also one student who was noted to not have a return of funds who did require a return of funds
based on testing, resulting in questioned costs. The sample was not considered statistically valid.
Recommendation: The College should modify its procedures for refunding awards to ensure proper
date computations, as well as disbursing refunds in a timely manner.
Management Response: Going forward, all students who withdraw from the College will be forwarded
to the financial aid team to review whether a student is still eligible for the full funding of the specific
semester in question or whether funding needs to be returned based on the withdrawal date. If it is
deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of
the student charges for that period and the Registrar will provide proof of the withdrawal date and the
financial aid team will determine the amount of funding that needs to be returned. Financial aid will
then complete the return through the student's account and notify the Controller and VP of Finance
and Administration to process the return to G5.