Finding Text
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 funds 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 nine students 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. Repeat Finding: This is a repeat finding from the previous audit, 2021-002. 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. Response: The College has well defined policies and procedures that outline attendance requirements (policy 2.61) and the process for administratively withdrawing students (policy 2.64) who have met the criterion for 14 consecutive calendar days of non-attendance. Instructors are required to adhere to College policies. The College has systems defined for producing a report of students who have officially and unofficially withdrawn and procedures for reviewing if a return of funds calculation is required. However, changes presented to schools with the Return of Funds regulations in early summer were difficult to understand and to incorporate pertaining to the new module language. Though we provided consistent methodology in line with our interpretations of the rules, we continued to evaluate our interpretation through various instruction from FSA handbook and webinars, NASFAA University Classes, NASFAA webinars and state association colleagues. Due to our hesitation to calculate a return of funds incorrectly, we had instances where the 45 days was exceeded. With regards to our calculations and reviews, we erred on the side of taking the needed time to confirm we had the correct calculation for the student versus calculating the percentage incorrectly and causing an increased balance for the student. We followed up with the Kansas City Department of Education Office and received final clarification our understanding of the new rules