Compliance Findings & Resolutions, Part 1 of 3

Carla Arsaga -

By Sherri Savasta

Reeling from the results of an audit or a Department of Education program review and in need of resources to provide assistance?

Since 1996, Global Financial Aid Services has provided consulting support in resolving compliance findings. Our team members bring years of experience to our solutions and familiarity with all aid delivery options for all size institutions.

Our first in a series of blogs outlines recent audit determinations and program review findings and details how Global Consulting can lend valuable assistance to your financial aid team.

Here are some of the findings for fiscal year 2023 that Global can help your college resolve:

1. Student Status Reporting is Inaccurate or Untimely

2. R2T4 Calculation Errors

3. R2T4 Funds Made Late

4. Entrance/Exit Counseling Deficiencies

5. Lack of Administrative Capabilities

6. Consumer Information Requirements Not Met

7. Verification or C-Flag Violations

8. Crime Awareness Requirements Not Met

9. Clock to Credit Hour Conversion

10.  Awarding/Disbursement Errors

Financial aid administrators can download a complete list of final audit determinations and the department’s final program review findings for fiscal year 2023 here.

In this blog, we will review the first three findings and Global’s support offerings.

1. Student Status Reporting is Inaccurate or Untimely
Finding Detail – If your institution is cited for this finding, resolution will require updates to the inaccurate information. If there are material instances, a file review of like students could be required. Cited data elements could include enrollment status, enrollment dates, LDAs, program level dates, student-specific late reporting and late submission of NSLDS enrollment roster files.

Global Offering – Global can prepare reconstructions in this area or evaluate the institution’s workflow outcomes and processes to determine where deficiencies exist.

2. R2T4 Calculation Errors
Finding Detail – A student who withdraws during a payment period or period of enrollment must have an R2T4 calculation completed to determine the amount of Title IV assistance earned by the student for the time completed.

  • This entails applying the correct percentage to the amounts of aid disbursed or that could have been disbursed.
  • Cited data inaccuracies include:
    1. Number of days in payment period/period of enrollment
    2. Clock hours (payment period)
    3. Withdrawal date
    4. Aid used as “could have been disbursed”
    5. Post-withdrawal disbursement
  • Mathematical and rounding errors.
  • Incomplete R2T4 policy.

Global Offering – Global can prepare reconstructions or evaluate institutional errors and design training. Global offers processing R2T4 calculations going forward as a stand-alone process.

3. R2T4 Funds Made Late
Finding Detail – After completion of an R2T4 calculation upon a student’s withdrawal from a payment period/period of enrollment, the institution must determine Title IV aid earned, as well as any unearned aid. Any unearned aid must be returned as soon as possible but no later than 45 days after the determination that the student withdrew. Errors in this process can include:

  • The institution’s policy and procedures are not followed.
  • An inadequate system is in place to identify and track official and unofficial withdrawals.
  • No system is in place to track the number of days remaining to return Title IV funds to the department.

Global Offering – Global can prepare reconstructions in this area or evaluate the institution’s workflow outcomes and processes to determine where deficiencies exist.

Please look for upcoming blogs on other compliance findings and Global’s consulting service offerings.

For assistance, contact Sherri Savasta at (228) 523-1072, ssavasta@globalfas.com or https://globalfas.com/contact

Sherri Savasta is Global’s Director of Consulting. She has been with Global since 2006, bringing in-depth experience to financial aid processing solutions.