Finding 1161061 (2024-007)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-10-20
Audit: 371029
Auditor: RBT CPA'S LLP

AI Summary

  • Core Issue: Delays in reporting Pell Grant disbursements to the COD system, with 14% submitted late.
  • Impacted Requirements: Compliance with 34 CFR 690.83(b)(2) for timely reporting within 15 days.
  • Recommended Follow-Up: Improve internal controls, set up automated alerts, conduct regular reconciliations, and enhance staff training on deadlines.

Finding Text

Program: Federal Pell Grant Program (CFDA #84.063) Criteria: Per 34 CFR 690.83(b)(2), institutions are required to submit Pell Grant disbursement records to the U.S. Department of Education’s Common Origination and Disbursement (COD) System no later than 15 calendar days after making a disbursement to a student. Timely reporting ensures accurate tracking of awards and compliance with federal regulations. Condition: During our testing of Federal Pell Grant disbursements, we identified delays in reporting disbursement information to COD. Out of a sample of 40 Pell Grant disbursements reviewed, 3 (approximately 14%) were submitted between 17 and 29 calendar days after the disbursement date, exceeding the required 15-day window. Cause: There was a technical glitch when the college used a batch process through Banner. The processed picked up every other student but did not include these three when it created the output file for an unknow reason. The college submitted each record individually as soon as they were made aware that the disbursement information was never sent to COD through their own internal review. Effect: Late reporting of Pell Grant disbursements may result in discrepancies between the institution’s records and the COD system, potentially affecting institutional eligibility, reconciliation accuracy, and future funding. Questioned Costs: None. Although reporting was delayed, all disbursements were ultimately submitted and accepted by COD. Perspective: This is a systemic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the College enhance internal controls to ensure Pell Grant disbursements are reported to COD within the required 15-day timeframe. This may include establishing automated alerts for pending disbursements, performing regular reconciliation with COD, and providing additional staff training on federal reporting deadlines.

Corrective Action Plan

Condition: Pell Grant disbursement data was not submitted to COD within the 15-day federal requirement due to a system error. Corrective Action: The Financial Aid Office, in collaboration with Bursar, will implement an automated alert system to flag pending COD submissions and conduct reconcilitions twice monthly. Responsible Party: Director of Financial Aid and Bursar Completion Date: January 31, 2026 Monitoring: Monthly COD reporting review with Vice President for Administration & Finance.

Categories

Reporting Student Financial Aid Eligibility

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $2.11M
84.268 Federal Direct Student Loans $801,164
93.558 Temporary Assistance for Needy Families $120,099
84.007 Federal Supplemental Educational Opportunity Grants $47,616
84.033 Federal Work-Study Program $27,584
17.259 Wioa Youth Activities $24,584
17.278 Wioa Dislocated Worker Formula Grants $15,532
17.258 Wioa Adult Program $14,126
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $4,514