2024-001 Reporting
U.S. Department of Education:
Student Financial Assistance Cluster – Federal Pell Grant Program (ALN 84.063)
Federal Award Number and Year: P063P241813 (7/1/23 – 6/30/24)
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Prior Year Finding: 2023-003
Finding Type: Material Weakness and Material Noncompliance
Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the COD system. Origination records can be sent well in advance of any disbursements, as early
as the institution chooses to submit them for any student the institution reasonably believes will be eligible
for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven
calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring
1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash
Monitoring 2 Payment Method (see Federal Register, Volume 85, Number 134, July 14, 2020). The
disbursement record reports the actual disbursement date and the amount of the disbursement. ED
processes origination and/or disbursement records and returns acknowledgments to the institution. The
acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or
Accepted. Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously reported
student disbursement data or expected student disbursement data. Institutions may do this by reporting
once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes
are reported in a timely manner.
Additionally, in accordance with Federal requirements, the University shall maintain internal controls over
Federal programs designed to provide reasonable assurance that the Pell reporting requirements are
executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award that could have a direct and material effect on a Federal program.
Condition and Context
The University has a process in place to submit the required information to COD on a weekly basis. For the
40 selections we tested, there were 8 instances of noncompliance exceptions where the University failed to
report student disbursement data related to Pell Awards within 15 calendar days. Additionally, the University did not properly maintain evidence that they had a control in place to review the ED
acknowledgement reports and to ensure disbursement data was reported within the 15 calendar day
requirement.
The University’s policies and procedures to ensure compliance with the above requirements did not include
procedures to properly maintain for the existence of a control or that the control was being performed.
Cause
The University did not have a process in place to maintain the documentation regarding the existence or
performance of the control.
Effect
The University is not in compliance with the Federal requirements to report disbursement data and maintain
documentation of its internal controls over the 15 calendar day reporting compliance requirement.
Questioned Costs
None
Recommendation
We recommend that the University strengthen its policies, procedures and controls over Pell reporting in
relation to the Student Financial Assistance Cluster. We also recommend that the University ensure that
internal controls in place surrounding the 15 calendar day reporting process are performed as designed
and documentation is maintained.
Views of Responsible Official
The University agrees with the finding. The University has had a significant amount of staff turnover and
reorganization in fiscal year 2024 in the financial aid office. The Interim Director of Financial Aid is
collaborating with the Controller’s office to make sure that the University has internal controls in place over
Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal
statutes, regulation and terms and conditions of the Federal award. The University is investing in making
sure that the Financial Aid Office is staffed and creates policies and procedures that assure that we
improve internal controls over the Pell reporting process.
U.S. Department of Education:
Student Financial Assistance Cluster – Federal Direct Student Loans (ALN 84.268)
Federal Award Number and Year: P268K241813 (7/1/23 – 6/30/24)
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Prior Year Finding: Not applicable
Finding Type: Significant Deficiency
Criteria
In determining loan amounts for Direct Subsidized Loans, the financial aid administrator subtracts from the
COA, the EFC, and the EFA for the period of enrollment that the student (or parent on behalf of the
student) will receive from Federal, state, institutional or other sources. Direct Unsubsidized Loans, Direct
PLUS Loans, TEACH Grants, loans made by an institution to assist the student, state-sponsored loans,
private education loans, and any other non-need-based loans may be used to replace the EFC (34 CFR
685.102(b)). A financial aid administrator may use professional judgment to offer dependent-level Direct
Unsubsidized Loans (but no other Title IV aid) to a dependent student whose parents do not support the
student or who refuse to complete a FAFSA (20 USC 1087(a)).
The annual loan limits apply to the length of the institution’s academic year. Except for Direct PLUS loans
and Direct Unsubsidized Loans made to graduate or professional students, proration of the annual loan
limit is required when a program is less than an academic year as measured in either clock hours or credit
hours or number of weeks; or when a program exceeds an academic year but the remaining portion of the
program is less than an academic year in length. For the purpose of determining annual loan limits for a
borrower who received an associate or bachelor’s degree and has re-enrolled in another eligible program
for which the prior degree is a prerequisite, the grade level determination includes the number of years that
a student has completed in the previously completed program of undergraduate study.
In addition to the requirements and limits described below, awards must be coordinated among the various
programs and with other Federal and nonfederal aid (need and non-need based aid) to ensure that total aid
is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and
FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301).
Condition and Context
The University has a process in place which exception reports are reviewed by an authorized financial aid
counselor to ensure they are completed timely and ensure students are eligible to receive Federal aid
disbursements. For the 45 selections we tested, we noted one instance where the University’s process in
place failed to identify the total aid awarded was in excess of the student’s financial need or cost of
attendance. The aid disbursed in excess of the student’s financial need or cost of attendance was $283.
The control did not operate effectively to detect the over award.
Cause
An incorrect budgetary item was utilized when calculating the student need based aid on the academic
year 2024 cost of attendance for this individual student resulting in an award amount larger than needed for
Federal unsubsidized direct loans.
Effect
Total aid in excess of the student’s financial need or cost of attendance was disbursed.
Questioned Costs
Not applicable as the finding is a significant deficiency.
Recommendation
We recommend that the University strengthen its controls in place to ensure the review is performed at a
precision to detect awarding and disbursing aid in excess of student’s financial need or cost of attendance.
Views of Responsible Official
The University agrees with the finding. The University has had a significant amount of staff turnover and
reorganization in fiscal year 2024 in the financial aid office. The Interim Director of Financial Aid is
collaborating with the Controller’s office to make sure that the University has internal controls in place over
Federal programs to assure that requirements are executed in compliance with Federal statutes, regulation
and terms and conditions of the Federal award. The University is investing in making sure that the Financial
Aid Office is staffed and creates policies and procedures that ensure that we improve internal controls over
the Eligibility and Cost of Attendance process.
2024-001 Reporting
U.S. Department of Education:
Student Financial Assistance Cluster – Federal Pell Grant Program (ALN 84.063)
Federal Award Number and Year: P063P241813 (7/1/23 – 6/30/24)
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Prior Year Finding: 2023-003
Finding Type: Material Weakness and Material Noncompliance
Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the COD system. Origination records can be sent well in advance of any disbursements, as early
as the institution chooses to submit them for any student the institution reasonably believes will be eligible
for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven
calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring
1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash
Monitoring 2 Payment Method (see Federal Register, Volume 85, Number 134, July 14, 2020). The
disbursement record reports the actual disbursement date and the amount of the disbursement. ED
processes origination and/or disbursement records and returns acknowledgments to the institution. The
acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or
Accepted. Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously reported
student disbursement data or expected student disbursement data. Institutions may do this by reporting
once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes
are reported in a timely manner.
Additionally, in accordance with Federal requirements, the University shall maintain internal controls over
Federal programs designed to provide reasonable assurance that the Pell reporting requirements are
executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award that could have a direct and material effect on a Federal program.
Condition and Context
The University has a process in place to submit the required information to COD on a weekly basis. For the
40 selections we tested, there were 8 instances of noncompliance exceptions where the University failed to
report student disbursement data related to Pell Awards within 15 calendar days. Additionally, the University did not properly maintain evidence that they had a control in place to review the ED
acknowledgement reports and to ensure disbursement data was reported within the 15 calendar day
requirement.
The University’s policies and procedures to ensure compliance with the above requirements did not include
procedures to properly maintain for the existence of a control or that the control was being performed.
Cause
The University did not have a process in place to maintain the documentation regarding the existence or
performance of the control.
Effect
The University is not in compliance with the Federal requirements to report disbursement data and maintain
documentation of its internal controls over the 15 calendar day reporting compliance requirement.
Questioned Costs
None
Recommendation
We recommend that the University strengthen its policies, procedures and controls over Pell reporting in
relation to the Student Financial Assistance Cluster. We also recommend that the University ensure that
internal controls in place surrounding the 15 calendar day reporting process are performed as designed
and documentation is maintained.
Views of Responsible Official
The University agrees with the finding. The University has had a significant amount of staff turnover and
reorganization in fiscal year 2024 in the financial aid office. The Interim Director of Financial Aid is
collaborating with the Controller’s office to make sure that the University has internal controls in place over
Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal
statutes, regulation and terms and conditions of the Federal award. The University is investing in making
sure that the Financial Aid Office is staffed and creates policies and procedures that assure that we
improve internal controls over the Pell reporting process.
U.S. Department of Education:
Student Financial Assistance Cluster – Federal Direct Student Loans (ALN 84.268)
Federal Award Number and Year: P268K241813 (7/1/23 – 6/30/24)
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Prior Year Finding: Not applicable
Finding Type: Significant Deficiency
Criteria
In determining loan amounts for Direct Subsidized Loans, the financial aid administrator subtracts from the
COA, the EFC, and the EFA for the period of enrollment that the student (or parent on behalf of the
student) will receive from Federal, state, institutional or other sources. Direct Unsubsidized Loans, Direct
PLUS Loans, TEACH Grants, loans made by an institution to assist the student, state-sponsored loans,
private education loans, and any other non-need-based loans may be used to replace the EFC (34 CFR
685.102(b)). A financial aid administrator may use professional judgment to offer dependent-level Direct
Unsubsidized Loans (but no other Title IV aid) to a dependent student whose parents do not support the
student or who refuse to complete a FAFSA (20 USC 1087(a)).
The annual loan limits apply to the length of the institution’s academic year. Except for Direct PLUS loans
and Direct Unsubsidized Loans made to graduate or professional students, proration of the annual loan
limit is required when a program is less than an academic year as measured in either clock hours or credit
hours or number of weeks; or when a program exceeds an academic year but the remaining portion of the
program is less than an academic year in length. For the purpose of determining annual loan limits for a
borrower who received an associate or bachelor’s degree and has re-enrolled in another eligible program
for which the prior degree is a prerequisite, the grade level determination includes the number of years that
a student has completed in the previously completed program of undergraduate study.
In addition to the requirements and limits described below, awards must be coordinated among the various
programs and with other Federal and nonfederal aid (need and non-need based aid) to ensure that total aid
is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and
FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301).
Condition and Context
The University has a process in place which exception reports are reviewed by an authorized financial aid
counselor to ensure they are completed timely and ensure students are eligible to receive Federal aid
disbursements. For the 45 selections we tested, we noted one instance where the University’s process in
place failed to identify the total aid awarded was in excess of the student’s financial need or cost of
attendance. The aid disbursed in excess of the student’s financial need or cost of attendance was $283.
The control did not operate effectively to detect the over award.
Cause
An incorrect budgetary item was utilized when calculating the student need based aid on the academic
year 2024 cost of attendance for this individual student resulting in an award amount larger than needed for
Federal unsubsidized direct loans.
Effect
Total aid in excess of the student’s financial need or cost of attendance was disbursed.
Questioned Costs
Not applicable as the finding is a significant deficiency.
Recommendation
We recommend that the University strengthen its controls in place to ensure the review is performed at a
precision to detect awarding and disbursing aid in excess of student’s financial need or cost of attendance.
Views of Responsible Official
The University agrees with the finding. The University has had a significant amount of staff turnover and
reorganization in fiscal year 2024 in the financial aid office. The Interim Director of Financial Aid is
collaborating with the Controller’s office to make sure that the University has internal controls in place over
Federal programs to assure that requirements are executed in compliance with Federal statutes, regulation
and terms and conditions of the Federal award. The University is investing in making sure that the Financial
Aid Office is staffed and creates policies and procedures that ensure that we improve internal controls over
the Eligibility and Cost of Attendance process.