Finding Text
FINDING 2022-002 ? Special Tests and Provisions ? Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2021-22 Criteria: Per 34 CFR Section 668.22; 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. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated 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. Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition and context: A sample of 24 students who were recipients of Title IV funding and had withdrawn during the year was selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 59 total withdrawals. Student records were compared to the calculation of the return of Title IV funds. We noted that the identification of withdrawn students is not timely, therefore, the initial calculation to return Title IV was late for seven of the twenty-four selected for testing with four as official withdrawals and three as unofficial withdrawals. Questioned costs: None Effect: The College did not perform the Title IV calculation within a reasonable time, and as such the return of funds was delayed. Cause: This occurred because the process in place was not designed effectively to identify the withdrawal of students, either official or unofficial, to calculate the return of Title IV funds and to remit amounts on a timely basis. Repeat finding: Yes, 2021-002 Recommendation: We recommend the College implement a process to identify official and unofficial withdrawals on a timely basis and that the calculations be performed within the required timeframe. Views of responsible officials and planned corrective actions: Official Withdrawals: Financial Aid Counselors are responsible for the Identification of Official Withdrawals through the Attendance Pattern Comparison Report (APCR), which is run every Monday (or next business day). Each Counselor (control #1) is responsible for the performance of the R2T4 form for their respective students and forward to the designated Counselor (control #2) to ensure accuracy and completion. Control #2 is responsible to manually input the calculations into Datatel and ensure adjustments, if any, are processed and returned via COD. This action is to be completed and included in the next scheduled batch closure or no later than 45 days from the date of withdrawal. Unofficial Withdrawals: After final grades have been posted at the end of each session or semester, each counselor will review their respective students through student transcript, identify those with ?zero credits earned? and determine last date of attendance. Official Withdrawal procedures will then be performed. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS by the Financial Aid Coordinator (with FA Officer as alternate) within 45 days. Anticipated completion of the corrective action is expected by June 2023.