Finding Text
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022
Award Period: July 1, 2021 to June 30, 2022
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Additionally, per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance.
Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Questioned costs: N/A
Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.