Finding Text
Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063).
Criteria or Specific Requirement: L. Reporting – Financial Reporting – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”.
Condition: For certain students identified through our testing, a key item (enrollment date) in student Pell origination records submitted to the COD did not agree to university’s enrollment files.
Cause: Administrative oversight.
Effect or Possible Effect: The University is not in compliance with Pell origination reporting requirements. Failure to accurately update borrower origination information prior to COD submission could result in improper awards of Title IV funds.
Questioned Costs: None.
Context: For 2 of 25 students selected for disbursement testing, the University did not accurately report the student enrollment date to the Department of Education Common Origination and Disbursement website.
Identification of Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University ensure that disbursement records are submitted to COD no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.
Views of Responsible Officials: The University has evaluated its current practices to confirm student enrollment dates. As a result, the Office of Financial Aid will enhance its policies and procedures for processing Pell grant originations to ensure that accurate enrollment dates are recorded for reporting purposes. These enhancements will include updates to the university’s Pell processing procedures, conducting a simulation of the origination file prior to the official submission to the Common Origination Database (COD), additional training for staff, and implementing periodic secondary reviews.