Finding Text
Criteria or specific requirement: The Department of Education requires the College 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. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted two of the 20 Pell grant disbursements were not reported to COD timely. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned Costs: None
Context: During our eligibility testing, we noted two of 20 Pell disbursements were not reported to COD within 15 days of the disbursement date. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Cause: The College did not have proper control or procedures in place to verify disbursements were reported to COD within the required 15 days after disbursement.
Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: Yes. Prior year finding 2023-002.
Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control.
Views of responsible officials: There is no disagreement with the audit finding.