Audit 401131

Section III – Federal Award Findings and Questioned Costs Finding 2025-001 – Untimely Reporting of Disbursement Records Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing # 84.063 Award Title: Federal Pell Grant Program Award Years: 7/2024 – 6/2026 Criteria Federal Register Volume 86, Issue 119 (June 24, 2021) – 86 FR 33246: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to the U.S. Department of Education’s (ED) 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. Condition Of the population of students who were disbursed Federal Pell Grants and/or Direct Loans during the period January 1, 2025 through December 31, 2025, 25 students were selected to validate that the disbursement information was timely and accurately submitted to the COD system within 15 days of funds being disbursed to the student. Of the 25 students selected, 11 instances were noted in which disbursement information was not reported to the COD system within 15 days. The disbursement information was reported between 19 and 72 days after the disbursement occurred. Cause, For 10 of the 11 instances that occurred in January 2025, the individual responsible for disbursement origination, serving as the primary control owner, was unavailable to perform these responsibilities. As a result, certain disbursement originations were not completed or submitted within required timeframes. Ensign College (the College) did not have a trained backup individual or sufficient monitoring controls in place to ensure these processes were performed timely in the absence of the primary control owner. Additionally, there was one instance noted in September 2025 that was not reported to the COD as a result of human error. Effect The College’s failure to submit disbursement records within the required timeframe may result in the ED rejecting all or part of the reported disbursement and/or additional adverse actions in accordance with 34 CFR 668. Questioned Costs None. Repeat Finding in the Prior Year No. Recommendation We recommend that the College train additional personnel to perform disbursement originations and related COD disbursement controls to ensure that controls are performed accurately and within required timeframes, including during periods of personnel absences. We also recommend that a reconciliation between the Student Information System, PeopleSoft, and the COD system be performed regularly to ensure all disbursement originations are accurate and any discrepancies are identified and resolved timely. Management’s Views and Corrective Action Plan Management’s response is reported in management’s views and corrective action plan included at the end of this report.