Finding 1074101 (2023-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-09-23
Audit: 320442
Organization: Berkshire Community College (MA)

AI Summary

  • Core Issue: The College failed to report a Pell Grant disbursement to the Federal Government’s COD system within the required 15-day timeframe, with a delay of 22 days for one student.
  • Impacted Requirements: Compliance with 34 CFR 690.83(b) and Federal Register guidelines, which mandate timely reporting of disbursement records.
  • Recommended Follow-Up: Management should review and update reporting policies and procedures to ensure all Pell Grant disbursements are reported on time.

Finding Text

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): 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. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 1 student, out of a sample of 40, was not reported within the required timeframe by 22 days. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The College did not report Pell Grant disbursements to COD within the required time frame. Questioned Costs Not applicable   Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, was determined to be reported late to the COD by 22 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 497657 2023-001
    Significant Deficiency
  • 497658 2023-001
    Significant Deficiency
  • 497659 2023-002
    Significant Deficiency
  • 497660 2023-003
    Significant Deficiency
  • 497661 2023-004
    Significant Deficiency
  • 497662 2023-004
    Significant Deficiency
  • 1074099 2023-001
    Significant Deficiency
  • 1074100 2023-001
    Significant Deficiency
  • 1074102 2023-003
    Significant Deficiency
  • 1074103 2023-004
    Significant Deficiency
  • 1074104 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.99M
84.268 Federal Direct Student Loans $1.28M
84.425 Education Stabilization Fund $385,496
84.116 Fund for the Improvement of Postsecondary Education $350,000
84.042 Trio_student Support Services $296,694
84.033 Federal Work-Study Program $72,840
84.007 Federal Supplemental Educational Opportunity Grants $70,830
84.048 Career and Technical Education -- Basic Grants to States $68,320
93.732 Mental and Behavioral Health Education and Training Grants $64,875
17.261 Wia Pilots, Demonstrations, and Research Projects $28,953