Finding Text
2024-001 Reporting
U.S. Department of Education:
Student Financial Assistance Cluster – Federal Pell Grant Program (ALN 84.063)
Federal Award Number and Year: P063P241813 (7/1/23 – 6/30/24)
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Prior Year Finding: 2023-003
Finding Type: Material Weakness and Material Noncompliance
Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the COD system. Origination records can be sent well in advance of any disbursements, as early
as the institution chooses to submit them for any student the institution reasonably believes will be eligible
for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven
calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring
1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash
Monitoring 2 Payment Method (see Federal Register, Volume 85, Number 134, July 14, 2020). The
disbursement record reports the actual disbursement date and the amount of the disbursement. ED
processes origination and/or disbursement records and returns acknowledgments to the institution. The
acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or
Accepted. 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.
Additionally, in accordance with Federal requirements, the University shall maintain internal controls over
Federal programs designed to provide reasonable assurance that the Pell reporting requirements are
executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award that could have a direct and material effect on a Federal program.
Condition and Context
The University has a process in place to submit the required information to COD on a weekly basis. For the
40 selections we tested, there were 8 instances of noncompliance exceptions where the University failed to
report student disbursement data related to Pell Awards within 15 calendar days. Additionally, the University did not properly maintain evidence that they had a control in place to review the ED
acknowledgement reports and to ensure disbursement data was reported within the 15 calendar day
requirement.
The University’s policies and procedures to ensure compliance with the above requirements did not include
procedures to properly maintain for the existence of a control or that the control was being performed.
Cause
The University did not have a process in place to maintain the documentation regarding the existence or
performance of the control.
Effect
The University is not in compliance with the Federal requirements to report disbursement data and maintain
documentation of its internal controls over the 15 calendar day reporting compliance requirement.
Questioned Costs
None
Recommendation
We recommend that the University strengthen its policies, procedures and controls over Pell reporting in
relation to the Student Financial Assistance Cluster. We also recommend that the University ensure that
internal controls in place surrounding the 15 calendar day reporting process are performed as designed
and documentation is maintained.
Views of Responsible Official
The University agrees with the finding. The University has had a significant amount of staff turnover and
reorganization in fiscal year 2024 in the financial aid office. The Interim Director of Financial Aid is
collaborating with the Controller’s office to make sure that the University has internal controls in place over
Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal
statutes, regulation and terms and conditions of the Federal award. The University is investing in making
sure that the Financial Aid Office is staffed and creates policies and procedures that assure that we
improve internal controls over the Pell reporting process.