Finding Text
Criteria or Specific Requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 34 CFR 690.83(b)(2), the College is required to report the disbursement dates and amounts awarded for Pell awards to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell funds to a student. Condition: The College did not report certain Pell disbursements within 15 days to COD. Questioned costs: None Context: For 1 of the 18 Pell disbursements tested across a sample of 32 students receiving Pell awards, the College did not report a disbursement within the 15 day requirement. Cause: The Pell grant was awarded after the fall semester had ended, so the College waited to make sure the student was enrolled for the spring semester before applying it. Effect: The College is not in compliance with required reporting to the Department of Education. Repeat Finding: No. Recommendation: We recommend the College ensure that a process is in place to report within 15 days, including a process to respond and report timely when there are student irregularities. Views of Responsible Officials: There is no disagreement with the audit finding.