Finding Text
2024-003 – Incorrect Calculation of Title IV Refunds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a 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 a payment period or period of enrollment and the number of calendar days completed in that period (34 CFR Section 668.22(f)(2)(i)). For a student that ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is the date that the student provided official notification to the institution, in writing or really, of his or her intent to withdraw (CFR Section 668.22(c)(1)(ii)). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. From these calculations we noted the following: Spring break of nine days was deducted incorrectly as seven days instead of nine for the three students who withdrew during spring semester. One student’s date of withdrawal was incorrect on the refund calculation. Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the conditions listed above: The University’s spring break was for the period of February 24, 2024 through March 3, 2024, a nine consecutive calendar day period. However, the University did not include the first two weekend days and calculated the break as seven days instead of nine. Due to this error, the correct number of days for the break was not deducted from the total number of calendar days properly for purposes of calculating refunds. One student’s withdrawal date was entered incorrectly in the R2T4 calculation. Effect: Refunds were calculated incorrectly for three of the four students that required refund calculations resulting in an incorrect amount of funds returned to the student and the Department of Education. Recommendation: We recommend procedures are put in place to ensure accuracy of R2T4 calculations. Action Taken: The Director of Financial Aid as well as the Data Analyst who is responsible for calculating the Return of Title 4 refunds have retaken the training module on calculating R2T4’s and counting days. This process was done manually allowing for marginal errors. Currently we have moved the process to be calculated automatically within our financial aid system which will reduce the margin of errors immensely and dates would be calculated correctly. This too will be affected by the revision of the new attendance policy. Responsible Party and contact information: Valerie Souza, FA Business Systems Analyst and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: The process has been instituted and has gone into effect immediately.