Finding Text
Program Information:
Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination.
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition:
The Organization did not properly calculate the amounts to be returned to the ED.
Cause:
Administrative oversight with respect to return of Title IV fund calculations and post-withdrawal disbursements.
Effect or Potential Effect:
The Organization was not in compliance with the return of Title IV funds requirements.
Questioned Costs:
None.
Context:
For 2 of 9 students selected for testing, the Organization did not properly calculate the amount of Title IV aid to be returned to the ED. The amount returned to the ED was greater than the amount owed based upon the students’ withdrawal date.
Identification of Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the Organization enhance its procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately.
Views of Responsible Officials and Planned Corrective Actions:
In fiscal year 2023 (FY23), the return of federal funds calculation and process was automated in the Banner student information system; therefore, reducing the possibility of an incorrect calculation. Furthermore, a financial aid staff member reviewed the return of federal funds calculations twice during the fiscal year to ensure accuracy. However, it was determined that two of the students selected in the FY23 audit sample had incorrect academic dates used in their calculation. As a graduate/professional school, PCOM has several academic calendars rather than one institutional calendar. The need for multiple academic calendars is due to the variations in the start and end times of our students completing offsite clinical rotations.
For fiscal year 2024 (FY24), PCOM will be implementing the following additional controls to ensure the correct academic calendar is used in the return of title 4 calculations: 1. Academic calendar dates will be added to the report used to review students who have withdrawn from their coursework. 2. The report will be run after the end of every term (4 times a year) and it will go through an initial review by one staff member and then a final review by another staff member.