Oklahoma Panhandle State UniversityHigher Education

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A243438 - 2025, P033A243438 - 2025, P063P242047 - 2025, P268K252047 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding:  Compliance, Other Matter  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Context: During our testing of 40 students, we identified 2 students with effective dates reported to NSLDS that did not align with institutional records. Cause: The University didn't have proper procedures in place to verify students' status in NSLDS matched the institution’s records accurately. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes, 2024-004 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement. Questioned costs: N/A Known Likely Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan. Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem. Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds Repeat Finding No Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Views of Responsible Officials Agree

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Material Weakness Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms. Compliance Material Document judgment for your assessment Appears to be systemic. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations. Questioned costs: Known $5,095.00 Likely See Questioned Cost Tab Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds. Additionally, one R2T4 calculation did not have documentation of review." Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed. Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned. Repeat Finding Yes Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. " Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade. " Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding Yes Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Agree

Federal Agency US Department of Education Federal Program Name Higher Education Institutional Aid Assistance Listing Number 84.031S Federal Award Identification Number and Year P031S200249 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material known questioned costs-therefore we will document as a SD. Additionally the client provided narrative response documents that the project directors complete, but do not quantify actual hours charged to the grant. based on expenditure of grant funds and activities in narrative responses and performance reports the grant work is being adequately completed, but the quantified hour tracking is not present. As such, based on these factors we will consider this to be a significant deficiency. Compliance Not Material Document judgment for your assessment See line 28 for more detailed response Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known 12,965.60 Likely 333907.5 Context During our testing of 40 Payroll transactions, we identified 38 time and effort reports that were not documented properly to track hours worked on federal grant and did not have a documentation of review. Additionally during our testing of 1 key personnel with Level of Effort provisions in the grant award notification, we identified the key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The University did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The University could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Views of Responsible Officials Agree

Federal Agency US Department of Education Federal Program Name Higher Education Institutional Aid Assistance Listing Number 84.031S Federal Award Identification Number and Year P031S200249 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Allowable Costs Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance N/A - I/C Finding Only Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition The University did not review scholarship awards made with federal program funds. Questioned costs: N/A Known Likely Context During our testing of 8 scholarship transactions, we observed 8 instances where scholarship awards did not have evidence of review prior to the award of funds to students. Cause The University did adhere to existing controls in place to review the federal program scholarship awards. Effect Scholarships may be awarded that are disallowed from program funds and may go undetected for substantial periods of time. Repeat Finding No Recommendation We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds. Views of Responsible Officials Agree

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Higher Education Emergency Relief Fund (HEERF) Assistance Listing Number: 84.425 Federal Award Identification Number and Year: P425F200639 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are properly reviewed and submitted timely. Condition: The University lacked documentation of supervisory review and did not submit quarterly reports timely. Context: During our testing of two student quarterly reports, from a statistically valid sample, we noted two reports lacked documentation of supervisory review and one report was uploaded to the University's website after the required due date. During our testing of two institutional quarterly reports, from a statistically valid sample, we noted one report lacked documentation of supervisory review and two reports were uploaded to the University's website after the required due date. Questioned costs: None. Cause: Staffing shortages led to delays in timely posting of the reports on the University?s website and documentation of supervisory review of the reports. Effect: Lack of supervisory review could result in errors in the filed reports. The failure to timely submit required reports may lead to adverse action. Repeat Finding: No. Recommendation: We recommend that the University review and update current procedures to ensure HEERF program reporting requirements are completed timely and to ensure review of reports are documented. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster, CFDA Number 84.268 Federal Direct Student Loans, U.S. Department of Education Program Year 2018 - 2019 Criteria or Specific Requirement ? Special Tests: Disbursements to or on Behalf of Students, 34 CFR Section 668.165 "Condition ? The University does not have a process in place to notify the student, or parent, in writing of: 1) The date and amount of loan disbursements. 2) The student's right, or parent's right, to cancel all or a portion of the loan or loan disbursement. 3) The procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan." Questioned costs ? None Context ? Out of a population of 905 students receiving Student Financial Assistance, a sample of 40 students was selected for testing of disbursements. Our sample was not and was not intended to be statistically valid. Written notification meeting the requirements of 34 CFR Section 668.165 was not made to students receiving Federal Direct Student Loans. Effect ? Students receiving Federal Direct Student Loans were not properly notified of loan disbursements, right to cancel and cancellation procedures. Cause ? The Office of Financial Aid has not historically had a practice in place of making written notifications of loan disbursements, right to cancel and cancellation procedures to students receiving Federal Direct Student Loans. Identification as a repeat finding ? N/A Recommendation ? The Office of Financial Aid should establish a practice of loan disbursement notifications consistent with 34 CFR Section 668.165. Views of Responsible Officials and Planned Corrective Actions ? In adherence with Code of Federal Regulations (CFR) 668.165 to notify students of a disbursement of a loan to their student account, financial aid has put in place a process in Banner which generates an email to notify the student of their or their parent's rights upon disbursement of a Federal Direct Student Loan.

"Student Financial Assistance Cluster, CFDA Number 84.268 Federal Direct Student Loans, CFDA Number 84.063 Federal Pell Grant Program, CFDA Number 84.007 Federal Supplemental Educational Opportunity Grants, CFDA Number 84.038 Federal Perkins Loan Program U.S. Department of Education Program Year 2018-2019" Criteria or Specific Requirement ? Special Tests: Return of Title IV Funds 34 CFR Sections 668.22 Condition ? Three Return of Title IV calculations were not processed correctly. "Questioned costs ? Additional returns to the U.S. Department of Education for CFDA Number 84.268 Federal Direct Student Loans should have been made totaling $6,338 for the year ended June 30, 2019." Context ? Out of a population of 56 official and unofficial withdrawals of students receiving Student Financial Assistance, a sample of 6 student withdrawals was selected for testing. Our sample was not and was not intended to be statistically valid. Return of Title IV calculations were not completed as required for 2 unofficial student withdrawals. One Return of Title IV calculation was completed correctly, but subsequent to the return an additional disbursement of unsubsidized direct loans was made. The post-withdrawal disbursement was in excess of the amount of aid earned by the student. Effect ? Three Return of Title IV calculations were not processed correctly resulting in $6,338 of Federal Direct Student Loan funds being retained by the University rather than being returned to the U.S. Department of Education. Cause ? The University's Office of Financial Aid has not historically considered unofficial withdrawals when calculating Returns of Title IV Funds. A post-withdrawal disbursement was made inconsistent with a student's Return of Title IV calculation. Identification as a repeat finding ? N/A Recommendation ? The University's Office of Financial Aid should begin a process of identifying students who received Student Financial Assistance and unofficially withdrew from the University at the end of each semester. Return of Title IV calculations should be completed for students who unofficially withdrew during the semester based on the midpoint of the term or the last date of academic activity. Views of Responsible Officials and Planned Corrective Actions ? The financial aid office will implement a policy to process unofficial withdrawals at the end of each term for students receiving federal aid in order to process Return of Title IV calculations.