Finding Text
Federal Program Information:
Federal Pell Grant Program (ALN: 84.063) and Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting – Financial Reporting – Federal regulations require the University to submit origination and disbursement records for students to the Common Origination and Disbursement System (“COD”). Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Institutions must also submit disbursement records to the COD for students no earlier than 7 calendar days prior to the disbursement date, and no later than 15 calendar days after the institution makes a disbursement. Key items to test on disbursement records are disbursement date and amount.
Condition:
For certain students identified through our testing, errors were identified in key items reported to the COD in student origination and disbursement records. Additionally, the University failed to report disbursement records for certain students within the required timeframe.
Cause:
Insufficient administrative oversight and internal controls with respect to accurate reporting of federal award information.
Effect or Potential Effect:
The University was not in compliance with COD reporting requirements.
Questioned Costs:
None.
Context:
We noted the following exceptions during our testing:
• For 14 of 25 students selected for origination record testing, the student’s cost of attendance was inaccurately reported within COD.
• For 1 of 25 students selected for origination record testing, the “Academic End Date” was inaccurately reported within COD.
• For 1 of 25 students selected for disbursement record testing, the University did not submit required disbursement information within the required timeframe.
• For 7 of 25 students selected for disbursement record testing, the award disbursement date was inaccurately reported within COD.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and implement formal policies and procedures over the applicable compliance requirements to ensure origination and disbursement records are reported accurately and timely to COD for Direct Loan and Pell Grant recipients, in accordance with federal regulations.
Views of Responsible Officials:
The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS systems contributed to erroneous COA budgets.
The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel.
In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition from the use of PowerFaids to Ellucian Colleague for financial aid management.
Resulting from the work of FAS, the University will institute a systematic monthly reconciliation process to ensure consistency across all systems (COD, PowerFAIDS, Jenzabar and Colleague). This includes matching COA and disbursement records to ensure accuracy. To optimize workflow, we will establish a comprehensive calendar of disbursement and reporting deadlines, with routine internal audits every 30 days, starting April 2025. This measure will enforce accountability and timeliness in reporting. We will enhance integration between financial systems (Jenzabar and PowerFAIDS) to prevent data mismatches and streamline the reporting process.
In addition, we will leverage our partnership with FAS to conduct regular training sessions for staff across the Financial Aid, Registrar, and Finance Offices to ensure everyone is aware of compliance requirements and system functionalities. These training sessions will start May 2025.