Finding Text
SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV
Based on a population of 7 Return to Title IV students
Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded.
Criteria 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 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 this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) .
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student 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 (34 CFR 668.22(e)).
Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew.
An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid.
Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225.
Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section.
Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan