Finding Text
2023-001 – Return of Title IV Funds – Significant Deficiency in Internal Controls over Compliance
Student Financial Assistance Cluster
U.S Department of Education
Federal Assistance Listing Number: 84.063, 84.268
Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Federal Award Number: P063P220416, P268K230416
Award Year: 2022-23
Criteria: 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 (34 CFR 668.22). Per 34 CFR 668.22(c)(4), An institution not required to take attendance
must document a student's withdrawal date determined in accordance with 34 CFR 668.22(c) paragraphs
(1), (2) & (3) and maintain the documentation as of the date of the institution's determination that the
student withdrew as defined in 34 CFR 668.22(l)(3).
Condition/context: A sample of 7 students (6 official and 1 unofficial) out of a population of 35 students
who were identified by the University as having withdrawn from the institution during the fiscal year was
selected for testing. For the 6 official withdrawal selections, the University was unable to provide sufficient
evidence to support the withdrawal date used in the calculation of Title IV funds to be returned.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs: Undetermined
Cause/Effect: This occurred because of a lack of implementation of procedures and controls to ensure
records used in the calculation of title IV funds to be returned were properly maintained. There was turn
over during the fiscal year in the student financial aid department, and the University was also utilizing
third parties to assist in some student financial aid functions in the interim. Because procedures and
controls were not operating as intended, the University is unable to support the dates used to determine
the amount of Title IV funds earned and to be returned.
Repeat finding: No
Recommendation: We recommend the University further educate and train those involved in the
Financial Aid department regarding the return to Title IV requirements. We also recommend that the
University review procedures and controls and ensure they are properly designed and implemented to
ensure calculations are occurring accurately and timely, and that the support used to complete
calculations, including indication of withdrawal date, is properly documented and maintained.
Views of responsible officials and planned corrective actions: As of June 2023, the Financial Aid
department has a full-time Director, who is responsible for the Return to Title IV (R2T4) determinations.
Following the regulations set forth by the Department of Education on R2T4 calculations for schools not
required to take attendance, we have reviewed procedures and controls to ensure they are properly
designed and implemented to ensure calculations are occurring accurately and timely. Going forward, we
will ensure maintenance of proper documentation on students requiring a calculation, including indication
of withdrawal date. Potential R2T4 calculations audits are now run multiple times a week, and will
continue to be, in order to address timely calculations. The Director plans to continue education in the
area of R2T4 calculations to maintain the most accurate and updated information on the topic