McClintock & Associates

Title IV Compliance

The Findings Benchmark

Enter your last audit. We place it against schools your size and walk you through it on a 30-minute call.

Your results come on the call, in a readout meeting with our audit team. Nothing is scored on the website.

Built from 361 Title IV compliance audits across four Title IV volume bands, fiscal years ending 2023 through 2025. 84% carried at least one finding — and nearly one in three findings (32%) came back the following year.

Have us compare your audit to schools your size

Built from 361 Title IV compliance audits by the firm that has been doing them since 1975.

  • Your findings measured against the schools in your Title IV volume band
  • Which of your findings are the recurring kind, and at what rate
  • How much of your student population your audit actually tested
  • A readout our audit team builds for you and walks through on the call

2026 Edition

The finding

Most Schools Treat a Finding as an Error. The Data Says It's a Forecast.

Across three years of Title IV compliance audits, 84% of reports carried at least one finding. That number surprises nobody. This one does: when a school has a finding, there is roughly a one-in-three chance the same finding appears again the following year — and for the most common findings, it's closer to one in two.

A finding that recurs is not an error. It's a process that hasn't changed. And recurrence is what moves a school from "we cleaned it up" to a program review conversation.

84%

of audit reports carried at least one finding

2.5

average distinct findings per report

32%

of findings reappeared the next year

13%

median share of the Title IV population actually tested

Basis: 361 compliance audit reports covering 157 campus entities across 50 client organizations, fiscal years ending 2023 through 2025, representing $8.5B in Title IV disbursements and 718,638 Title IV students.

Where findings come from

Five Categories Account for Most of It

Share of reports carrying each finding category, fiscal years ending 2024 and 2025 (189 reports).

Share of audit reports carrying each finding category

FYE 2024–2025, n = 189 reports.
Show data table
Finding prevalence by category, FYE 2024–2025, n = 189 reports
Finding categoryShare of reportsReports
Pell Grant Award42.9%81 of 189
Direct Loan Award30.7%58 of 189
Resolution of a Credit Balance30.2%57 of 189
Enrollment Reporting Procedures27.0%51 of 189
Return to Title IV (R2T4) Calculation25.4%48 of 189
Late Return of Title IV Funds14.3%27 of 189
Exit Counseling12.7%24 of 189
Verification Procedures11.1%21 of 189
Disbursement Reporting Procedures10.6%20 of 189
Post-Withdrawal Disbursement9.0%17 of 189
The part nobody benchmarks

Which Findings Come Back

Credit balance resolution recurs in 58% of cases. Post-withdrawal disbursement recurs in 17%. Same audit report, very different meaning: the first usually points to a process that isn't there yet, the second to a one-time slip. Recurrence covers fiscal years ending 2023 through 2025.

Recurrence rate by finding category

Fiscal years ending 2023 through 2025, consecutive-year report pairs.
Show data table
Recurrence rate by finding category, consecutive-year report pairs
Finding categoryRecurrence rateRecurredOpportunities
Resolution of a Credit Balance58%3560
Pell Grant Award50%3264
Enrollment Reporting Procedures40%1743
Direct Loan Award38%2566
Return to Title IV (R2T4) Calculation36%1747
Late Return of Title IV Funds28%725
Verification Procedures22%523
Disbursement Reporting Procedures17%424
Post-Withdrawal Disbursement17%318

The question to ask your auditor.

Not "how many findings did we have." Ask: which of our findings are the recurring kind, and what would have to change operationally for them not to come back? If the answer is a corrective action plan that reads like last year's, the finding is going to recur.

Scale changes the picture

Bigger Programs Don't Get Cleaner, They Get Broader

Average distinct findings per report by annual Title IV volume, fiscal years ending 2023 through 2025. The smaller bands average 2 to 3 findings per report; the largest, closer to 4.

Average distinct findings per report by Title IV volume

Average distinct findings per report by annual Title IV volume, fiscal years ending 2023 through 2025.
Show data table
Findings by Title IV volume cohort
CohortReportsAvg findingsMedian findings% with 1+% cleanMedian coverage
Under $5M672.40276%24%25.9%
$5M–$15M592.54290%10%12.9%
$15M–$30M292.90390%10%6.8%
$30M and above343.88394%6%1.4%
What the sample doesn't tell you

Your Findings Describe 13% of Your Students

A compliance audit tests a median of 90 files — a median 13% of the Title IV population — turning up a median 2.0 finding instances per 50 files tested.

At a 1,400-student school where 90 files were tested, applying that rate to the 1,310 files nobody looked at implies roughly 50 more files carrying the same kinds of issues.

Sample sizes are set by your population, so this isn't about asking your auditor to test more. It's about knowing that the files nobody looked at run through the same processes as the ones that were cited.

An illustrative extrapolation from sample finding rates, not a statistical projection or an estimate of liability. Audit samples are drawn at random and sized by the population; findings describe the files tested, not the ones that weren't.

What to do with this

Three Things, in Order

  1. 1.

    Separate your findings into recurring and non-recurring.

    Pull the last three audit reports and mark every finding that appears more than once — that list is the actual risk register. The rest is noise.

  2. 2.

    For each recurring finding, name the process — not the person.

    A finding that recurs after remediation means the remediation was a correction, not a control.

  3. 3.

    Test past the sample before your next fieldwork.

    Your sample is set by your population, so this isn't about asking your auditor to test more. Pick the controls behind your findings and review a set of files the audit didn't reach.

What to measure

Recurring findings as a share of total findings

Tells you whether prior fixes were controls or one-time corrections.

Your distinct findings against the median for your Title IV volume band

Compares you to schools that administer a program the size of yours, rather than to the sector as a whole.

Finding instances per 50 files sampled

Separates a change in your operation from a change in how you were sampled.

Each one is derivable from the audit report you already receive, and together they tell you whether your compliance operation is improving or simply being sampled differently.

Who produced this

50+

Years auditing Title IV

10

FAACs on staff

110+

Institutions served

150+

Audits annually

We're available 365 days a year to keep you ahead of regulatory changes.

A readout built around schools your size.

Enter your last audit and we'll place it against the schools in your Title IV volume band, work out which of your findings are the recurring kind, and walk you through the three questions we'd ask if we were reading your report — on a 30-minute call. We do not return any of this on a web page. No cost, no obligation to change auditors.