Finding Text
Treatment of Title IV Funds when a Student Withdraws (Significant Deficiency) Department of Education, SFA Cluster Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic funds transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR 668.173(b). Condition: Eleven of the seventeen students selected for withdraw testing for the 2022-2023 academic year required a return of funds to the Department of Education. Return of Title IV funds occurred untimely for two students, exceeding 45 days as required, when considering the University’s date of determination as reported on R2T4 forms. Cause: The University does not have adequate procedures in place to ensure students’ Title IV funds are returned timely. R2T4 forms improperly reported the date of determination the same as the student withdraw date. Effect: The University failed to return Title IV funds to the Department of Education within 45 days of the students’ date of determination as reported on the R2T4 forms. Recommendation: We recommend that the University put procedures in place to ensure that R2T4 forms are filed timely and properly reflect the University’s date of determination for all student withdrawals. Management Response: Management determined the root cause of errors in the date of determination that the student withdrew (determination date), which ultimately led to funds not being returned within 45 days, was due to a process error. The old process relied on the Registrar’s Office to provide the actual date to use (through a Withdrawal Report). It was discovered that with only one date able to be captured in the current (antiquated) ERP that the Date of Withdrawal was the only date provided. In the short term, this is being resolved by the Registrar’s Office directly notifying the Financial Aid Office with both dates (not relying on a withdrawal report): Date of Withdrawal and Date of School’s Determination. Beginning 2024‑5 a new ERP will be in place that will allow both dates to show in the Financial Aid R2T4 module immediately as reported from the Registrar’s Office.