Finding 1105163 (2024-001)

Compliance Requirement: Reporting Criteria Per 34 CFR 668, Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. In addition, CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‑Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Found The University did not have controls appropriately designed to ensure timely reporting of disbursements to the Department of Education Common Origination and Disbursement (COD) system. Specifically, during our testing, we selected a sample of 40 students to recalculate the days between disbursements and the reporting of disbursements to COD. Three of our selections (two graduate students and one undergraduate student) were not submitted within the required 15-day window. These students were part of a population that the University attempted to submit to COD timely but, due to system errors, that submission was not transmitted. The University later discovered this and resubmitted the information 4 days after the due date. The University’s controls were not designed to ensure those errors were resolved timely. Cause and Effect The University did not design its controls to ensure error reports with the COD were resolved on a timely basis to ensure disbursements were reported on a timely basis. Each of the errors were resolved and information was ultimately reported to the COD, however, not within the 15-day window. Repeat Finding This finding is not a repeat finding in the immediately prior audit. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University improve related control to ensure disbursements are reported to the Department of Education within the 15-day requirement. Views of Responsible Officials The University agrees with the condition reported. The responsible department did initiate the student report transmittal to the COD, however a system error prevented it from reaching the COD. The University updated its control processes to ensure the COD confirms receipt of the student report transmittals to mitigate such errors for future reporting.