Finding Text
Finding 2022-001: Special Tests: Return of Title IV Funds - Significant Deficiency in Internal Control Over Compliance - See Schedule of Findings and Questioned Costs for table. Criteria ? An institution must return the total amount of unearned Title IV assistance. 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). An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR section 668.22(j)). Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic funds transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew (34 CFR section 668.173(b)). Condition/context ? From a population of approximately 84 students who were recipients of Title IV funding and had either unofficially or officially withdrawn during the fiscal year ended June 30, 2022, we selected 11 students for testing by comparing student records to the calculation of the return of Title IV funds, if any, and to the federal government?s Common Origination and Disbursement system. From our testing, we noted one instance where the return to Title IV calculation was completed accurately but funds, totaling $1,118, were not returned within 45 days after the date of the University?s determination that the student withdrew. Effect ? The University did not return certain Title IV funds timely to the U.S. Department of Education. Cause ? The finding occurred due to lack of adherence to the University?s policies and procedures over return of Title IV funds and inconsistencies in performance of processing due to employee turnover in both the Registrar?s office and the Financial Aid office. Repeat finding ? This is not a repeat finding. Questioned costs ? None. Recommendation ? We recommend that the University revise and strengthen its policies and procedures over return of Title IV funds to ensure the process is fully completed are returned within 45 days of determining the student?s withdrawal date. Views of responsible officials and planned corrective actions ? The University concurs with this finding. Management has implemented continual training and education of current policies and procedures and is developing additional procedures to ensure the return to Title IV process is fully completed included verifying that funds due to the U.S. Department of Education are returned timely.