Finding Text
Compliance Finding and Significant Deficiency - 2022-001 U.S. Department of Education Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.033, 84.063 & 84.268 Award Year: 2021-2022 2022-001 Special Test and Provisions - Return of Title IV Funds Criteria: In accordance with 34 CFR 668.173(b), the College must return Title IV fund within 45 days after the date the College determined the student withdrew. Additionally, the College is considered an attendance taking school, therefore, they must make the determination that the student withdrew no later than 14 days after the student's last date of attendance as determined by the College from its attendance records. Condition: The College did not return unearned Title IV funds within the prescribed timeframe. Context: A sample of 25 R2T4 calculations revealed that one student had Title IV funds returned later than the allowable timeframe. All funds were returned in the proper order and amount. Effect: Title IV funds were not returned in a timely manner. Cause: The College did not have specific procedures in place to ensure timely reporting of withdraws by instructors, which in turn, did not provide enough time for the College to identify, prepare, and return funds within the required timeframe. Questioned Costs: The questioned costs would be insignificant due to the funds being returned in the proper order and amount. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 668.173 as it relates to the return of Title IV funds. College Response: The College has well defined policies and procedures that outline attendance requirements and the process for administratively withdrawing students who have met the criterion for 14 consecutive days of non-attendance. Instructors are required to adhere to the College policies. As referenced in 34 CFR 668.173(c)(2), "The Secretary does not consider an institution to be out of compliance with the reserve standard under 68.173(a)(3) if the institution is cited in any audit or review report because it did not return unearned funds in a timely manner for only one or two students, or for less than 5% of the students in the sample referred to in paragraph (c)(1)(i) of this section". This audit indicates that only one student was found outside of the allowable timeframe in the sample. The College understands the necessity to reduce any issues with return of funds and will continue to work with instructors on a regular basis to adhere to the policies and procedures established to stay in compliance with these regulations.