Finding Text
Finding 2023-002
Programs Affected
U.S. Department of Education – Student Financial Assistance Cluster – Award Year July 1, 2022 – June 30, 2023.
Criteria
According to 34 CFR section 668.22, a school is required to determine the earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student is in attendance or, in the case of a clock-hour program, was scheduled to be in attendance.
34 CFR Section 668.2 (f)(2)(i) further states that the total number of calendar days in a payment period or period of enrollment includes all days within the period that the 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.
Condition
While testing return of Title IV funds, a nonstatistical sample of 6 students was tested for proper return calculations. During the testing, we noted the calculation for the 2022 fall semester return of funds was based on an incorrect number of days due to the inclusion of the academic break surrounding the Thanksgiving holiday. From the total population of students that had a return of Title IV funds, 25 students who withdrew were impacted, resulting in additional funds needing to be returned to the Department of Education.
This prompted the University to review the 2023 spring semester return of funds as well, which caused seven more students who withdrew to be impacted, resulting in additional funds needing to be returned to the Department of Education.
Cause
The calculation of total days was miscalculated causing the percentage earned and unearned by Title IV students that withdrew.
Questioned Costs
$5,875; $5,743 for the fall semester and $132 for the spring semester.
Effect
Students withdrawing had improper calculations of aid earned and unearned due to the miscalculated total number of days.
Fall semester had 25 students and spring semester had 7 students that needed to have the return of Title IV funds calculation re-performed. All 32 students required more funds to be returned to the Department of Education. The University returned the funds using institutional funds.
Recommendation
BerryDunn recommends the return of Title IV funds worksheet include a documented review process around parameters for academic breaks included in a semester.
Views of Responsible Officials and Corrective Action Plan
Management agrees with the finding. See attached Corrective Action Plan.