Finding Text
2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal
Controls over Compliance and Material Noncompliance
Student Financial Assistance Cluster
Department of Education
Federal Assistance Listing Number: 84.063, 84.268, 84.007
95
Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Supplemental Educational
Opportunity Grant
Criteria – In accordance with 34 CFR 668.22 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 grant or loan assistance that the student earned as of the
student’s withdrawal date.
Condition/context – The College is not properly identifying students who have withdrawn from the institution for
whom a R2T4 calculation is necessary. The College was unable to provide a complete population of official and
unofficial withdrawals with accurate withdrawal dates for testing.
Questioned costs – Undeterminable.
Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting
documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance
requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the
federal government, or eligibility for post withdrawal disbursement. As a result, we were unable to determine if the
College is remitting unearned funds to the federal government, or offering eligible students post withdrawal
disbursements if available to them.
Repeat finding – No
Recommendation – We recommend the College review their policies, procedures and controls to ensure students
who have withdrawn from the institution are being identified, and that R2T4 calculations are performed and
maintained for those students. We also recommend the College ensure all withdrawals have the appropriate
documentation to support the withdrawal date used in the calculation.
Views of responsible officials and planned corrective actions –
Responsible Individuals: Michael N. Espinoza, Vice President of Student Services
Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and
awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed
correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.
Develop and implement ongoing tracking and reporting for all financial aid reporting.
Financial Aid and Student Accounts work to regularly review and action student account files.
Continue to work with third-party service to review and promptly return Title IV funding in compliance with
federal rulings.
Anticipated Completion Date: to be completed by June 30, 2024