Finding No. 2022-001 CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate recordkeeping . Criteria According to 34 CFR 668.164 an institution must disburse during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student's parent, is eligible to receive for that payment period. Condition During our disbursement test we found 1 case out of 60 tested on which the student?s COD listed two disbursements on June 13, 2022, one for $2,435.00 and another for $3,247.50, but on the student?s ledger only one disbursement was listed for $2,435.00. The student was eligible to receive the $2,435, but not the $3,247.50. Cause Both disbursements were made on the same date; however, inadvertently the correct steps were not performed in ED Express in order for the return to be processed. Effect The Institution must return the amount of over award and could be subject to additional monitoring by the Department as well as penalties and/or safeguards such as letters of credit. Questioned Cost $3,247.50 Recommendation The Institution must reinforce disbursement control procedures to ensure that all disbursements are correctly posted and the amounts between COD and student?s ledger are a match. Management Response and Corrective Action Plan See Corrective Action Plan for Management?s response
Finding No. 2022-002 CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping . Criteria According to Federal Register (86 FR 33245) an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Condition During our disbursement test we found 2 cases out of 60 tested on which the disbursement date on the students? ledger and COD did not match and furthermore, had a discrepancy of more than 15 days. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Effect The Institution could be subject to additional monitoring by the Department as well as penalties and/or safeguards such as letters of credit. Questioned Cost $0 Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursements and trace dates between COD and student?s ledger. Management Response and Corrective Action Plan See Corrective Action Plan for Management?s response
Finding No. 2022-001 CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate recordkeeping . Criteria According to 34 CFR 668.164 an institution must disburse during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student's parent, is eligible to receive for that payment period. Condition During our disbursement test we found 1 case out of 60 tested on which the student?s COD listed two disbursements on June 13, 2022, one for $2,435.00 and another for $3,247.50, but on the student?s ledger only one disbursement was listed for $2,435.00. The student was eligible to receive the $2,435, but not the $3,247.50. Cause Both disbursements were made on the same date; however, inadvertently the correct steps were not performed in ED Express in order for the return to be processed. Effect The Institution must return the amount of over award and could be subject to additional monitoring by the Department as well as penalties and/or safeguards such as letters of credit. Questioned Cost $3,247.50 Recommendation The Institution must reinforce disbursement control procedures to ensure that all disbursements are correctly posted and the amounts between COD and student?s ledger are a match. Management Response and Corrective Action Plan See Corrective Action Plan for Management?s response
Finding No. 2022-002 CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping . Criteria According to Federal Register (86 FR 33245) an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Condition During our disbursement test we found 2 cases out of 60 tested on which the disbursement date on the students? ledger and COD did not match and furthermore, had a discrepancy of more than 15 days. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Effect The Institution could be subject to additional monitoring by the Department as well as penalties and/or safeguards such as letters of credit. Questioned Cost $0 Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursements and trace dates between COD and student?s ledger. Management Response and Corrective Action Plan See Corrective Action Plan for Management?s response