Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-007 Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdrawals, or expresses notification to withdrawal, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Seminary did not have a control in place to maintain documentation of the student financial aid department's review and consideration on the applicability of a return to title IV calculation. Subsequent to the fiscal year, the Seminary reviewed the original data files produced throughout the year by the registrar and updated documentation to support compliance. This assessment resulted in no students identified during testing that required a calculation to be performed. Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner. Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student's individual facts and circumstances including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal. Views of Responsible Officials and Planned Corrective Actions - The financial aid director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. The registrar will continue to email financial aid with any withdrawal details.