Finding 2023-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Pell Grant Program (84.063)
Federal Direct Loan Program (84.268)
Federal Award Year: 2021-2022
Criteria and Context:
Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (“COD”) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution credits a student’s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department.
Condition, Cause, and Effect:
During our testing surrounding the College’s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 87, Number 105. Of the one hundred eleven (111) individual Direct Loan disbursements for thirty-four (34) students selected for testing, we noted two (2) records that were not reported within the aforementioned 15-day timeframe. These two (2) Direct Loan records were reported two hundred seventy-three (273) days after the actual disbursement date. Of the thirty-eight (38) individual Pell Grant disbursements for twenty-one (21) students selected for testing, we noted two (2) records that were not reported within the aforementioned 15-day timeframe. These two (2) Pell Grant records were reported between thirty-two (32) and thirty-nine (39) days after the actual disbursement date.
Questioned Costs:
None noted
Identified as a Repeat Finding:
Yes
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.
Finding 2023-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Pell Grant Program (84.063)
Federal Direct Loan Program (84.268)
Federal Award Year: 2021-2022
Criteria and Context:
Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (“COD”) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution credits a student’s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department.
Condition, Cause, and Effect:
During our testing surrounding the College’s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 87, Number 105. Of the one hundred eleven (111) individual Direct Loan disbursements for thirty-four (34) students selected for testing, we noted two (2) records that were not reported within the aforementioned 15-day timeframe. These two (2) Direct Loan records were reported two hundred seventy-three (273) days after the actual disbursement date. Of the thirty-eight (38) individual Pell Grant disbursements for twenty-one (21) students selected for testing, we noted two (2) records that were not reported within the aforementioned 15-day timeframe. These two (2) Pell Grant records were reported between thirty-two (32) and thirty-nine (39) days after the actual disbursement date.
Questioned Costs:
None noted
Identified as a Repeat Finding:
Yes
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.
Finding 2023-002 - Reporting (Control Deficiency)
U.S. Department of Education – Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”)
Student Aid Portion (84.425E)
Institutional Portion (84.425F)
Minority Serving Institutions (84.425L)
Federal Award Year: 2022-2023
Criteria and Context:
HEERF reporting requirements include three components: 1) public reporting on Student Aid; public reporting on the Institution Portion and subprograms, as applicable; and 3) the annual report. Public reporting on the student aid and institutional portions is required to be posted to the institution’s website and updated no later than 10 days after the end of each calendar quarter. Previously, institutions were required to publicly post on their websites two separate reports documenting their expenditures of student and institutional portions of funds, respectively. Effective for the Q2 2022 report required to be posted by July 10, 2022, the U.S. Department of Education (“ED”) instituted a new quarterly reporting form that captures spending of both student and institutional funds. Quarterly reports should appear on separate documents by quarter and should not be cumulative.
Condition, Cause, and Effect:
During our testing, we noted that the College did not submit a quarterly report for the quarter ended
March 31, 2023, as required. Instead, the College combined the reporting activity for the quarters ended March 31, 2023 and June 30, 2023 in the Q2 2023 report.
Questioned Costs:
None noted
Identified as a Repeat Finding:
No
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of HEERF quarterly reports to ensure such information is submitted within the appropriate timeframe.
Finding 2023-002 - Reporting (Control Deficiency)
U.S. Department of Education – Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”)
Student Aid Portion (84.425E)
Institutional Portion (84.425F)
Minority Serving Institutions (84.425L)
Federal Award Year: 2022-2023
Criteria and Context:
HEERF reporting requirements include three components: 1) public reporting on Student Aid; public reporting on the Institution Portion and subprograms, as applicable; and 3) the annual report. Public reporting on the student aid and institutional portions is required to be posted to the institution’s website and updated no later than 10 days after the end of each calendar quarter. Previously, institutions were required to publicly post on their websites two separate reports documenting their expenditures of student and institutional portions of funds, respectively. Effective for the Q2 2022 report required to be posted by July 10, 2022, the U.S. Department of Education (“ED”) instituted a new quarterly reporting form that captures spending of both student and institutional funds. Quarterly reports should appear on separate documents by quarter and should not be cumulative.
Condition, Cause, and Effect:
During our testing, we noted that the College did not submit a quarterly report for the quarter ended
March 31, 2023, as required. Instead, the College combined the reporting activity for the quarters ended March 31, 2023 and June 30, 2023 in the Q2 2023 report.
Questioned Costs:
None noted
Identified as a Repeat Finding:
No
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of HEERF quarterly reports to ensure such information is submitted within the appropriate timeframe.
Finding 2023-002 - Reporting (Control Deficiency)
U.S. Department of Education – Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”)
Student Aid Portion (84.425E)
Institutional Portion (84.425F)
Minority Serving Institutions (84.425L)
Federal Award Year: 2022-2023
Criteria and Context:
HEERF reporting requirements include three components: 1) public reporting on Student Aid; public reporting on the Institution Portion and subprograms, as applicable; and 3) the annual report. Public reporting on the student aid and institutional portions is required to be posted to the institution’s website and updated no later than 10 days after the end of each calendar quarter. Previously, institutions were required to publicly post on their websites two separate reports documenting their expenditures of student and institutional portions of funds, respectively. Effective for the Q2 2022 report required to be posted by July 10, 2022, the U.S. Department of Education (“ED”) instituted a new quarterly reporting form that captures spending of both student and institutional funds. Quarterly reports should appear on separate documents by quarter and should not be cumulative.
Condition, Cause, and Effect:
During our testing, we noted that the College did not submit a quarterly report for the quarter ended
March 31, 2023, as required. Instead, the College combined the reporting activity for the quarters ended March 31, 2023 and June 30, 2023 in the Q2 2023 report.
Questioned Costs:
None noted
Identified as a Repeat Finding:
No
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of HEERF quarterly reports to ensure such information is submitted within the appropriate timeframe.
Finding 2023-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Pell Grant Program (84.063)
Federal Direct Loan Program (84.268)
Federal Award Year: 2021-2022
Criteria and Context:
Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (“COD”) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution credits a student’s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department.
Condition, Cause, and Effect:
During our testing surrounding the College’s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 87, Number 105. Of the one hundred eleven (111) individual Direct Loan disbursements for thirty-four (34) students selected for testing, we noted two (2) records that were not reported within the aforementioned 15-day timeframe. These two (2) Direct Loan records were reported two hundred seventy-three (273) days after the actual disbursement date. Of the thirty-eight (38) individual Pell Grant disbursements for twenty-one (21) students selected for testing, we noted two (2) records that were not reported within the aforementioned 15-day timeframe. These two (2) Pell Grant records were reported between thirty-two (32) and thirty-nine (39) days after the actual disbursement date.
Questioned Costs:
None noted
Identified as a Repeat Finding:
Yes
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.
Finding 2023-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Pell Grant Program (84.063)
Federal Direct Loan Program (84.268)
Federal Award Year: 2021-2022
Criteria and Context:
Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (“COD”) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution credits a student’s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department.
Condition, Cause, and Effect:
During our testing surrounding the College’s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 87, Number 105. Of the one hundred eleven (111) individual Direct Loan disbursements for thirty-four (34) students selected for testing, we noted two (2) records that were not reported within the aforementioned 15-day timeframe. These two (2) Direct Loan records were reported two hundred seventy-three (273) days after the actual disbursement date. Of the thirty-eight (38) individual Pell Grant disbursements for twenty-one (21) students selected for testing, we noted two (2) records that were not reported within the aforementioned 15-day timeframe. These two (2) Pell Grant records were reported between thirty-two (32) and thirty-nine (39) days after the actual disbursement date.
Questioned Costs:
None noted
Identified as a Repeat Finding:
Yes
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.
Finding 2023-002 - Reporting (Control Deficiency)
U.S. Department of Education – Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”)
Student Aid Portion (84.425E)
Institutional Portion (84.425F)
Minority Serving Institutions (84.425L)
Federal Award Year: 2022-2023
Criteria and Context:
HEERF reporting requirements include three components: 1) public reporting on Student Aid; public reporting on the Institution Portion and subprograms, as applicable; and 3) the annual report. Public reporting on the student aid and institutional portions is required to be posted to the institution’s website and updated no later than 10 days after the end of each calendar quarter. Previously, institutions were required to publicly post on their websites two separate reports documenting their expenditures of student and institutional portions of funds, respectively. Effective for the Q2 2022 report required to be posted by July 10, 2022, the U.S. Department of Education (“ED”) instituted a new quarterly reporting form that captures spending of both student and institutional funds. Quarterly reports should appear on separate documents by quarter and should not be cumulative.
Condition, Cause, and Effect:
During our testing, we noted that the College did not submit a quarterly report for the quarter ended
March 31, 2023, as required. Instead, the College combined the reporting activity for the quarters ended March 31, 2023 and June 30, 2023 in the Q2 2023 report.
Questioned Costs:
None noted
Identified as a Repeat Finding:
No
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of HEERF quarterly reports to ensure such information is submitted within the appropriate timeframe.
Finding 2023-002 - Reporting (Control Deficiency)
U.S. Department of Education – Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”)
Student Aid Portion (84.425E)
Institutional Portion (84.425F)
Minority Serving Institutions (84.425L)
Federal Award Year: 2022-2023
Criteria and Context:
HEERF reporting requirements include three components: 1) public reporting on Student Aid; public reporting on the Institution Portion and subprograms, as applicable; and 3) the annual report. Public reporting on the student aid and institutional portions is required to be posted to the institution’s website and updated no later than 10 days after the end of each calendar quarter. Previously, institutions were required to publicly post on their websites two separate reports documenting their expenditures of student and institutional portions of funds, respectively. Effective for the Q2 2022 report required to be posted by July 10, 2022, the U.S. Department of Education (“ED”) instituted a new quarterly reporting form that captures spending of both student and institutional funds. Quarterly reports should appear on separate documents by quarter and should not be cumulative.
Condition, Cause, and Effect:
During our testing, we noted that the College did not submit a quarterly report for the quarter ended
March 31, 2023, as required. Instead, the College combined the reporting activity for the quarters ended March 31, 2023 and June 30, 2023 in the Q2 2023 report.
Questioned Costs:
None noted
Identified as a Repeat Finding:
No
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of HEERF quarterly reports to ensure such information is submitted within the appropriate timeframe.
Finding 2023-002 - Reporting (Control Deficiency)
U.S. Department of Education – Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”)
Student Aid Portion (84.425E)
Institutional Portion (84.425F)
Minority Serving Institutions (84.425L)
Federal Award Year: 2022-2023
Criteria and Context:
HEERF reporting requirements include three components: 1) public reporting on Student Aid; public reporting on the Institution Portion and subprograms, as applicable; and 3) the annual report. Public reporting on the student aid and institutional portions is required to be posted to the institution’s website and updated no later than 10 days after the end of each calendar quarter. Previously, institutions were required to publicly post on their websites two separate reports documenting their expenditures of student and institutional portions of funds, respectively. Effective for the Q2 2022 report required to be posted by July 10, 2022, the U.S. Department of Education (“ED”) instituted a new quarterly reporting form that captures spending of both student and institutional funds. Quarterly reports should appear on separate documents by quarter and should not be cumulative.
Condition, Cause, and Effect:
During our testing, we noted that the College did not submit a quarterly report for the quarter ended
March 31, 2023, as required. Instead, the College combined the reporting activity for the quarters ended March 31, 2023 and June 30, 2023 in the Q2 2023 report.
Questioned Costs:
None noted
Identified as a Repeat Finding:
No
Recommendation:
The College should review the effectiveness of its internal controls governing the timely submission of HEERF quarterly reports to ensure such information is submitted within the appropriate timeframe.