Finding Text
Criteria
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 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 we noted two students’ calculations out of a sample of forty 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. 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
$590
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
employee turnover in fiscal year 2023. The Associate Director tasked with checking the refunds
did not do as thorough a job as management was led to believe and separated from the College
just before the end of FY23. The remaining staff was challenged to learn and process the Return
of Title IV calculations in a short turnaround, while being short-staffed.