Core Issue: The College failed to return unearned Title IV funds for one student withdrawal, leading to non-compliance.
Impacted Requirements: The College did not meet 34 CFR 668.22(a)(1) through (a)(5) and 34 CFR 668.173(b) regarding timely returns of funds.
Recommended Follow-Up: Management should establish procedures to ensure timely calculation and processing of Title IV fund returns upon student withdrawals.
Finding Text
United States Department of Education
Federal Program: Student Financial Assistance Cluster
Reference Number: 2023-002
Federal Award Identifiers: P007A229034; P033A229034; P063P226291; P268K236291
Type of Finding: Non-Compliance and Significant Deficiency in Internal Control
Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds
Condition: One of three student withdrawals selected for testing required a return of unearned Title IV funds.
This student’s unearned Title IV Funds were not returned.
Context: The College correctly calculated the unearned Title IV Funds upon the student’s withdrawal. The
College did not process the return of funds in Common Origination and Disbursements. Fifteen students that
received Title IV funds withdrew during the year ended June 30, 2023.
Criteria: 34 CFR 668.22(a)(1) through (a)(5) requires the College to calculate and return unearned Title IV
Funds. 34 CFR 668.173(b) requires the College to return the unearned Title IV Funds no later than 45 days after
the date the College determines that the student withdrew.
Questioned Costs: $3,359 of unearned Title IV Funds for one student were not reported or returned.
Cause: A shortage of staff resulted in the control deficiency.
Effect: The College did not timely report return of unearned Title IV Fund resulting in an overstatement of the
students’ federal loan balances.
Recommendation: We recommend management implement procedures to ensure returns of Title IV Funds are
timely calculated and processed upon student withdrawal.
Categories
Questioned CostsInternal Control / Segregation of DutiesSpecial Tests & ProvisionsStudent Financial AidReportingSignificant DeficiencyMatching / Level of Effort / Earmarking