Finding Text
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.