Finding 2025-001 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 Award Year: 2024-2025 Criteria: Under the Federal Pell Grant program, institutions are required to report enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus-Level” and “Program-Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. When a Federal Loan is made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceases to be enrolled on at least a half- time basis or fails to enroll on at least a half-time basis for the period for which the loan is intended, or a student who is enrolled at the institution and who receives a loan under Title IV has changes his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Context: Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant 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: During our testing surrounding the University’s COD reporting process, the University did not report all Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 87, Number 105. Of the thirty-two (32) individual Pell Grant disbursements for seventeen (17) students selected for testing, we noted three (3) records that were not reported within the aforementioned 15-day timeframe. These three (3) Pell Grant records were reported between fifty-six (56) and one hundred thirty (130) days after the actual disbursement date. Cause: The condition was due to ineffective controls over the timeliness of COD reporting, including the absence of a formal monitoring process to track and ensure Pell disbursements were reported within required timeframes. In addition, processes and controls were not adequately updated to reflect the Department of Education’s temporary extension of reporting requirements, and late submissions were not timely identified and remediated through supervisory review. Effect: The University did not accurately report enrollment status for three (3) of the students tested within the required timeframe. Questioned Costs: None noted. Identified as a Repeat Finding: No. Recommendation: The University should review the effectiveness of its internal controls governing the timely submission of Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe. Views of Responsible Officials and Planned Corrective Action: Management agrees with the findings and recommendations. The University has implemented corrective actions to prevent recurrence by transitioning Pell Grant processing to a fully automated system that interfaces directly with the COD system. This change is expected to reduce manual intervention, minimize errors, and improve compliance, with completion anticipated within 18 months and ongoing monitoring by Financial Aid and IT.