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, 34 CFR 690.83, require the College to submit origination 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”. Condition: For certain disbursements identified through our testing, errors were identified in key items reported to the COD in student origination records. Cause: Insufficient administrative oversight and internal controls with respect to accurate reporting of federal award information. Effect or Potential Effect: The College was not in compliance with COD reporting requirements. Questioned Costs: None. Context: We noted the following exceptions during our testing: • For 3 of 25 origination records tested, the student’s cost of attendance was not accurately reported. • For 1 of 25 origination records tested, the academic end date was not accurately reported. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the College enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure origination records are reported accurately and timely to the COD for Direct Loan and Pell Grant recipients, in accordance with federal regulations. Views of Responsible Officials: The College acknowledges the reporting errors identified in certain student origination records submitted to the Common Origination and Disbursement (COD) System, specifically related to cost of attendance and academic end date data elements. To address this finding, the College will enhance internal controls and oversight over federal aid reporting by implementing the following corrective actions: • Establish a documented secondary review process for all origination records prior to submission to COD, with verification of key data elements including cost of attendance, academic start and end dates, enrollment status, and award amounts. • Implement a standardized review checklist to ensure accuracy and completeness of required data fields. • Strengthen reconciliation procedures between the student information system and COD to identify and resolve discrepancies timely. • Conduct periodic internal quality assurance reviews of origination and disbursement records. • Provide additional staff training on federal reporting requirements.