Finding Text
PROCEDURES USED TO IDENTIFY STUDENTS FOR THE RETURN OF TITLE IV FUNDS
SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
CFDA # 84.268
(Questioned Costs-Undetermined)
(Repeat) Condition:
When a recipient of Title IV grant or loan assistance withdraws from an institution of higher learning during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in the regulations.
During our audit we noted that the University’s did not perform the R2T4 calculations in a timely manner as required by the Department of Education regulations.
Context:
Review of internal controls and related procedures in place for identifying students ceasing to attend or enroll and the procedures in place to identify when a student withdraws or fail to properly enroll. Policies in place to determine the timeliness of calculating the required return of federal funds as prescribed by the Department of Education.
Criteria:
Controls should be in place to ensure that when a student ceases to attend the University the proper procedures are followed.
The financial aid personnel and the accounting department and the management accounting systems of each non-Federal entity must provide for, effective controls over, and accountability for all students the withdraws from the University [2 CFR §668.22].
Effect:
Management may not be able to obtain complete and accurate information to determine when a student withdraws from the University and therefore, not properly calculate the R2T4 funds.
Cause:
Turnover in the student financial aid department and weaknesses in processes related to procedures determining official withdrawals, un-official withdrawals and students failing to return for the next semester. Recommendation: The policies and procedures in place to identify students withdrawing from the University should be reviewed and improved to ensure that when a student ceases to enroll or withdraws from the institution (officially or un-officially) the proper procedures are followed, as outlined in the federal regulations. Timely R2T4 calculations should be performed and appropriate grant or loan funds should be timely remitted back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions:
The University has implemented policy and procedures that require a review of all official and unofficial withdrawals to have R2T4 calculations on a real time basis to ensure compliance with the Department of Education guidelines on a consistent and regular basis. Internal audits of the process will also be implemented for continuous improvement.