Information on the Federal Program: Student Financial Aid Cluster (CFDA Numbers 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) – U.S. Department of Education – 2019 – 2020 Award Year
Criteria: Withdrawal date for a student who withdraws from an institution that is not required to take attendance-34 CFR 668.22(C)(4&5)-An institution must document a student's withdrawal date determined in accordance with paragraphs (c)(1), (2), and (3). For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student's withdrawal date is:
The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution;
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;
If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c) (1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period.
Scheduled breaks - 34 CFR 668.22(f)(2)(i) and (ii) (B) - Institutionally scheduled breaks of five or more consecutive days are excluded from the return of Title IV funds calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of federal aid earned.
Condition: During our testing of return of Title IV funds, we noted multiple control deficiencies and instances of noncompliance with federal compliance regulations surrounding the return of funds process.
Context: During our testing of return of funds, we selected seven students in our non-statistical sample from a total population of 79 withdrawn students to test for internal controls and compliance with federal regulations. We noted the following internal control deficiencies and compliance findings:
We noted there was no secondary, documented review of return of funds calculations to ensure accuracy and completeness of the calculation.
We noted five instances in which the University was unable to support the unofficial withdrawal date used within the return of funds calculation.
During our review of the calculation of days in the enrollment period for the Spring semester return of funds calculations, we noted the dates for Spring Break entered into Banner for break days did not align with the University's published academic calendar. We also noted the Sunday surrounding Spring Break where no regular classes are held was not properly accounted for resulting in a 2-day error in the days in enrollment period calculation for Spring semester withdrawn students. We noted four instances in our sample affected by this error.
Effect: The University may not comply with federal regulations and may not return or report the appropriate amount of unearned Title IV funds.
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