Finding Text
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require that, when there are Title IV
funds to be returned, that they be deposited or transferred into the student financial aid account or an electronic
funds transfer initiated to the Department of Education as soon as possible, but no later than 45 days after the
institution determines that a student withdrew.
Condition: There was one student where the College failed to initiate the electronic funds transfer to the
Department of Education within the 45-day timeframe.
Context: We addressed this matter with College management who are aware of the requirements of review of all
student withdrawals to determine Title IV refunds and timely return of funds.
Effect: Failure to properly review and adhere to policies and procedures can lead to noncompliance and the
misappropriation of federal funds that are not detected during the normal course of business.
Cause: The lack of compliance is due to the College failing to review student withdrawals in a timely manner.
Recommendation: We recommend the College review and update its policies and procedures to ensure all Title IV
funds are returned in a timely manner.
Views of Responsible Officials and Planned Corrective Action: We concur with the finding. The College is in
the process of implementing controls and procedures to ensure that all Title IV funds are properly monitored and
reviewed.
SECTION