Finding 957308 (2023-003)

According to 34 CFR 668.22(f)(2): (i) The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. (ii) The total number of calendar days in a payment period or period of enrollment does not include – (A) Days in which the student was on an approved leave of absence; or (B) For a payment period or period of enrollment in which any courses in the program are offered in modules, any scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time. According to 34 CFR 668.22(e)(4): Total amount of unearned Title IV assistance to be returned. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of Title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The federal government requires that when a student withdraws from classes, the College calculate the student’s percentage of Title IV aid earned. This is calculated by dividing the number of days the student attended classes by the total number of days in the academic period. The total number of days in the academic period (semester) includes all calendar days between the start and end of academic activities. The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G6”). During our testing of forty students, we noted: - One instance in which the incorrect number of total days in the semester was used to calculate the student’s percentage of Title IV aid earned. - One instance where the aid returned was different than the amount correctly calculated on the Return to Title IV (“R2T4”) form.Cause The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. In the instance of the incorrect number of days used in the calculation, the College incorrectly calculated the enrollment period due to the College utilizing the incorrect semester as basis for calculating Return of Title IV funds. The student enrolled and subsequently withdrew during Spring II semester, which is an accelerated program. However, the College utilized the traditional Spring semester number of days in its calculation. In the instance of the incorrect aid returned, the College did not ensure proper review of the refunding of the Title IV funds when calculating the amount of aid to be returned. Effect The College did not return the appropriate amount of Title IV funds to the Department of Education. Questioned Costs $950.81 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had refund amounts that were inaccurately returned to the federal government. Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should provide training to employees responsible for completing the Return of Title IV calculations and ensure that they have adequate knowledge in the related rules and regulations. The College should implement a formal review process of the Return of Title IV calculations by an individual with proper knowledge of the federal regulations. View of Responsible Officials The College agrees with the finding. The Student Financial Services department experienced significant employee turnover in fiscal year 2023. The remaining staff was challenged to learn and process the Return of Title IV calculations in a short turnaround, while being short-staffed.