Finding Text
Outstanding Student Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.007, 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement:
The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to
disburse funds by check and the check is not cashed, the institution must return the funds to the
Department of Education (ED) no later than 240 days after the date it issued that check.
Condition:
Title IV checks outstanding for 240 days were not returned to ED as of June 30, 2023.
Questioned Costs:
$3,753
Context:
During our testing, we noted 10 out of 10 Title IV checks older than 240 days which were not returned
to the ED.
Cause:
Management did have a process in place to return Title IV checks that were outstanding for 240 days or
more. However, the University did not ensure this process was being followed during the year and
verify the funds had been properly returned.
Effect:
The University is not in compliance with requirements to return Title IV refund checks outstanding more
than 240 days to the ED.
Repeat Finding:
No.Auditors’ Recommendation:
We recommend the University develop a process to ensure that all Title IV outstanding checks are
returned back to the ED within the required timeframe and verify on a regular basis the process has
been followed.
Views of Responsible Officials:
There is no disagreement with the finding.