Finding 2020-001: Return Of Title IV Funds

Condition: During the predecessor auditor's testing of return of Title IV funds, multiple control deficiencies and instances of noncompliance with federal compliance regulations were noted surrounding the return of funds process.

Predecessor Auditor's Recommendation: Predecessor auditor recommend the Financial Aid Office implement the following processes: 1.) a process to review the University's academic calendar and break days in the enrollment period to ensure the days in the enrollment period calculation is accurate and complete and consider Sundays surrounding Spring Break where there is no schedule classes; 2.) develop a timely secondary review process to detect potential errors and ensure return of funds calculation are completely entered into the Banner software; and 3.) develop a process to ensure appropriate supporting documentation is maintained to support withdrawal dates used in the return of funds calculation. Under the CARES Act passed in March 2020, institutions are not required to return Title IV funds under the waiver exception, however, the Department of Education has outlined specific reporting requirements under the CARES Act include: Identifying information for each student for whom R2T4 was waived under the CARES Act; the payment period "begin" and "end" dates for the period that the student did not complete as a result of the COVID-19 emergency; the amount of Title IV grant or loan assistance (other than Federal Work Study funds) that each such student received for the payment period in which he or she withdrew; and the total amount of Title IV grant or loan assistance that each institution has not returned to the Secretary as a result of the CARES Act provisions. Institutions should retain this information for each student who withdraws and qualifies for an R2T4 waiver under the CARES Act, and should plan to provide, for each student, identifying information, payment period begin and end dates, and information regarding the Title IV grant and loan disbursements (except for Federal Work Study) that the student received for the payment period. In order to fulfill the third reporting requirement, an institution must determine the total amount of grant and loan assistance that otherwise would have been returned, identified in Step 5 of the R2T4 calculation, had the calculation been performed. Therefore, it will continue to be necessary for institutions to perform an R2T4 calculation for each student covered by the CARES Act R2T4 waiver.

Status: Unresolved. See finding 2021-015.

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