Swarthmore College

2024 – 001 Title IV Credit Balance Refund Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV program funds by crediting a student's account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but— (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing, we noted one student's credit balance was not refunded within 14 days. Questioned costs: $3,711 Context: During our testing, we noted that one student was owed a Title IV credit refund as of January 2024 that was not refunded until April 2024. Cause: The report used by the College to monitor Title IV credit balance refunds, did not include all the information to capture this student. Effect: The College did not refund the student within 14 days. Repeat Finding: No. Recommendation: We recommend the College evaluate its policies and procedures to ensure there is a process in place to ensure timely refund of Title IV credit balances. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Title IV aid earned. When classes end on a Friday and do not resume until Monday following a one-week break, both weekends (four days) are excluded from the calculation. (34 CFR 668.22(f)(2)(i) and (ii)(B)) Condition: During our testing, we noted the College did not remove four days associated with the weekends from the R2T4 calculations for scheduled breaks. Questioned costs: $43 Context: During our testing, we noted the College did not correctly factor in scheduled breaks to the R2T4 calculations. Since class ended on a Friday and did not resume until the following Monday, both weekends (an additional 4 days) should have been included in the total number of days when excluding them from the calculation. As a result, three students out of a sample of five selected for testing did not have the correct number of days factored into their R2T4 calculations. Cause: The College did not include the correct number of days for scheduled breaks in the R2T4 calculations. Effect: The College did not complete an accurate calculation as defined by Federal regulations, resulting in a return of more aid than required. Repeat Finding: No. Recommendation: We recommend the College evaluate its policies and procedures surrounding the completion of R2T4 calculations to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a Roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. The ED requires institutions to report changes in enrollment status and indicate the date that the changes occurred. (34 CFR 685.309) Condition: Enrollment effective dates reported at the program and campus level did not agree. Questioned costs: N/A Context: We noted one student out of a sample of fifteen students tested whose program level enrollment effective date did not agree to the effective date at the campus level. Cause: There was a defect in the report utilized by the College to submit the enrollment information to the NSLDS. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the student’s grace period should begin. Repeat Finding: No. Recommendation: We recommend the College evaluate its policies and procedures in overseeing submissions to the NSLDS. In addition, we recommend the College review its policies and procedures on reporting enrollment information to the NSLDS to ensure all relevant information is being captured on reports utilized to submit data to the NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

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