Finding Text
2023-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford
Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063)
Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period
and/or period of enrollment completed, the total number of calendar days in a payment and/or
enrollment period includes all days within the period, except that institutionally scheduled breaks of
at least 5 consecutive calendar days and days in which the student was on an approved leave of
absence are excluded from the total number of calendar days in a payment period and/or period of
enrollment.
Statement of Condition: During the audit, it was noted that the University used the incorrect number
of total days in the payment period or period of enrollment in calculating the percentage of payment
period and/or period of enrollment completed for the Fall 2022 semester.
Questioned Costs: This finding is monetary in nature. In the instances noted in testing, the total error
identified is $116 in under-award. Extrapolation of this monetary error was not necessary as the 11
withdrawal students tested as part of the 2023 audit were the entire withdrawal population for the
period under audit.
Perspective Information: The audit included a detailed testing of 11 withdrawal student files, of
which this significant deficiency applies to 6, indicating an error rate of 54.6%.
Cause and Effect: For withdrawal calculations performed in the fall semester, the total day count was
not performed per the instructions described in the Student Financial Aid Handbook. The University
calculated using 109 days, while the actual number was 107 days. The use of an incorrect total
number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may
additionally result in monetary error.
Recommendation: The University should ensure that the total number of calendar days in the
payment period or period of enrollment are counted correctly utilizing the guidance provided by the
Compliance Supplement and the Student Financial Aid Handbook.
View of Responsible Officials: When setting the R2T4 dates in the system the University had failed to
count the Saturday and Sunday preceding the break period of five days or more. The University has
addressed the issue for the future POE periods and implemented a three-step verification process
moving forward. The three-step verification involves two additional staff verifying the dates in the
system to ensure accuracy.