Finding Text
Federal program information: Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster Assistance Listing number: 84.007, 84.033, 84.063, & 84.268 Award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Special Tests and Provisions Condition: In our testwork over the Return of Title IV funds, we noted the following noncompliance: ? In 3 out of 25 students examined, the College did not return the funds to the Department of Education in the required 45 days after the withdrawal date of the student. ? One student?s calculation of return of funds was incorrect, the amount of funds returned should have been $520 but $887 was returned to the Department of Education. The College did not make complete progress in fiscal year 2022. Criteria: According to 34 CFR 668.173(b), return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Education Department as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. According to 34 CFR 668.22(g), The institution must return the lesser of (1) the total amount of unearned Title IV assistance to be returned as described above, or (2) an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. If, for a non-term program, an institution chooses to calculate the treatment of Title IV assistance on a payment period basis, but the institution charges for a period that is longer than the payment period, ?total institutional charges incurred by the student for the payment period? is the greater of (1) the prorated amount of institutional charges for the longer period, or (2) the amount of Title IV assistance retained for institutional charges as of the student?s withdrawal date. Questioned Costs: None Effect: The College returned Title IV funds to the Department of Education later than the timeframe required by the program requirements and because of one student?s miscalculation of returned funds, the College sent $367 more to the Department of Education than the required amount. Cause: The College was late in sending the returned funds to the Department of Education for a few of our samples examined because the financial aid office was not made aware certain students were no longer attending the College until after the end of the semester. The calculated dates for return of funds are the last date the student attended the College which meant that the College?s staff would not be informed of the withdrawal until after the 45 days was lapsed. All three of these instances had money transferred within 45 days of the semester end. The incorrect calculation of the one student occurred when there was a change in the student?s status of loan funds awarded; the change was not updated appropriately in the College?s system (Colleague), which resulted in the incorrect calculation. Auditor?s Recommendations: We recommend that the College ensure that the professors inform the financial aid office as soon as a student is no longer attending classes so that the College can ensure they send the Return of Title IV funds within the required 45 days and that when calculating the return of funds, the staff review to ensure they have taken into account all changes of the student status. Agency Response: Management agrees with this finding to meet compliance with the 45 day return of Title IV funds. ? Financial Aid is running a weekly report to capture all students that have dropped/withdrawn from classes. At the end of the semester (fall, spring or summer), a report is run to identify withdrawals, failed, or incomplete grades to determine if a return of funds calculation is warranted. This became important with the impact of COVID-19 on students which caused disruptions and difficulty in managing course loads. Financial Aid processes had a built in assumption that failed grades were unearned but, in reviewing and updating our processes most failed grades are actually earned. The return of funds has traditionally been calculated with the assumption the student did not earn the failed grade so the mid-point of the term was used for last date of attendance. Financial Aid is updating processes based on actuals and will continue working with Learning on the most efficient methodology to determine if a student has earned a failed grade or has stopped attending during the semester. ? Financial Aid will generate a weekly report to identify student withdrawals utilizing a new reporting tool being implemented late 2021. With the enhanced reporting tool and changes in methodology and process?s, we fully anticipate the return of funds will be calculated and remitted to the Department of Education within the required time. ? The Financial Aid Office has communicated with the Vice-President of Learning about the necessity for proper reporting by faculty with regards to non-attendance reporting and last date of attendance. ? Timeline: Management has already implemented the corrective actions. ? Mindi Schrum, Sr. Director and/or Greg Gallegos, Assistant Director will oversee the implementation of these.