Finding Text
Finding 2022-001: Significant Deficiency ? Return of Title IV Funds Program: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K223683 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: In a sample of 15 students that withdrew during the fiscal year, the University did not perform the required return to Title IV calculations for four students who completed less than 49% of the payment period. For one additional student, a Title IV calculation was prepared, however the calculation was incorrect and an incorrect amount was returned. The sample was not a statistically valid sample. Cause: The University incorrectly interpreted the period of enrollment to be the one module and not the entire payment period for the withdrawal exemption for successful completion of 49% or more. The University?s interpretation was made in May 2021 and therefore impacts students in the 21-22 award year as well as in the 22-23 award year through March 1, 2023 when the error in interpretation was confirmed. Effect: The University incorrectly calculated students as having completed more than 49% and therefore did not perform R2T4 calculations or return unearned loan funds to the Department. Additionally, some R2T4 calculations were incorrect based on the calculation using only the module not the days in the payment period. Questioned costs: Total questioned costs were $10,819 of Direct Student Loan funds. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management's Response: Upon discovery of the errors, the University reviewed the population of withdrawn students where the dates for one module were used versus the payment period. The University performed the additional or revised Title IV calculations for five students and returned additional funds. The $10,819 reported as questioned costs identified by the auditors has also been returned. The university will also review 2022-23 award year of when the 49% exemption or one module in a payment period, and make any R2T4 corrections.