Community College District of Newton and McDonald Counties, MissouriHigher Education

Special Test and Provisions – Return of Title IV Funds U.S. Department of Education Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.033, 84.063 & 84.268 Award Year: 2024-2025 Significant Deficiency and Compliance Criteria: Under 34 CFR §668.22, the College is required to return Title IV funds in accordance with federal regulations governing the Return of Title IV (R2T4) calculation. This calculation determines the amount of unearned aid by subtracting the assistance earned by the student from the total aid disbursed. The percentage of earned and unearned funds is based on the student’s attendance within the College’s defined payment period. Condition: In a sample of 25 R2T4 calculations, it was determined that College entered the spring break dates incorrectly in the calculation, which resulted in 2 calculation errors. Cause: The College had a change to the academic calendar that did not get updated in the financial aid software. Effect: All students with withdrawal dates in the timeframe between the entered spring break and actual spring break, which was a one week difference, potentially had a calculation error on their R2T4. Questioned Costs: All questioned costs are below the known and likely questioned costs reporting threshold. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR §668.22 as it relates to calculations of return of Title IV funds. Response: The College reviewed all accounts affected by this error and identified 15 students whose accounts required adjustments. Upon review, the financial aid representative determined that excess funds were returned when the R2T4 calculations were completed. Financial Aid has since corrected the accounts and requested the additional funds owed. To prevent this issue from recurring, a representative from the Financial Aid Office will be included on the calendar committee. Additionally, Financial Aid Policies and Procedures have been updated to require calendar changes to be promptly updated in PowerFaids to ensure accuracy.

Criteria: The College is required to timely and accurately update changes in student enrollment information for periods during which the College was required and comply with enrollment reporting requirements in accordance with 34 CFR 690.83 and 34 CFR 685.309. Enrollment information must be reported within 60 days. Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Condition: The College has procedures in place to correctly report changes in student enrollment status within the required timeframe, but those procedures did not detect that enrollment status information was not provided within the required timeframe for all students. Context: A sample of 40 students revealed that enrollment status was not reported within the required timeframe for one student and one additional student did not have a record in Department of Education’s system. A non-statistical sampling methodology was used to select the sample. Effect: The Department of Education may be making decisions on incorrect or outdated information. Cause:  The College did not have specific procedures in place to properly report or review reports provided by a third-party servicer to the Department of Education. Questioned Costs: At most, questioned costs would be interest accrued on the outstanding amounts of direct student loans which are insignificant, therefore there are no questioned costs. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 690.83 and 34 CFR 685.309 as it relates to reporting enrollment information to the Department of Education. We further recommend the College follow the guidance provided in the NSLLDS Enrollment Reporting Guide and stay abreast of new guidance as published by the Department of Education. Response: The College will be taking extra measures to periodically review enrollment batches that are sent to the Clearinghouse, ensuring that they are being updated into NSLDS alongside any error reports that may be coming back from the Clearinghouse.  This will help prevent any unknown or missed student enrollment report from the Clearinghouse to NSLDS