Finding Text
Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loans Program (ALN 84.268) and Federal Pell Grant Program (ALN 84.063)
Federal Award Identification Number and Year -Various
Pass-through Entity -None
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student’s withdrawal (30 days if never attended) (34 CFR 668.220)(1)).
When a recipient of Title IV grant or loan assistance withdraws from an institution 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 an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)).
Condition - The College did not timely return the Title IV funds (R2T4) for 3 students.
Questioned Costs -None
Context -Of the 40 students tested, there were 3 students who withdrew and while the calculations of the amount to return were correct, the funds were not returned with 45 days of date of determination.
Cause and Effect - All of the untimely R2T4 refunds were during the fall semester when the College’s financial aid department was understaffed due to departures.
Recommendation - The College should try to incorporate R2T4 into a daily task for staff to ensure compliance with federal regulations are completed timely.
Views of Responsible Officials and Corrective Action Plan - As outlined in the audit finding, the auditors noted three of the forty R2T4 transactions reviewed (7.5%) were not completed within the required timeframe. We have reviewed these transactions and agree with the auditor’s determination. Given that only three calculations were identified as late, we consider these to be anomalies and not reflective of our overall operating practice. As the auditors state, all three of these transactions were calculated correctly and were all three associated with the Fall term. Since that time, we have instituted new processes to help ensure the timely processing of all R2T4 calculations. These new processes include cross-training of staff to help ensure complete coverage of duties regarding this task. In addition, financial aid staff relating to R2T4 activities have received additional training with a financial aid consultant to help ensure both timeliness and accuracy.