Finding Text
Assistance Listing, Federal Agency, and Program Name ALNs 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Significant deficiency Repeat Finding No Criteria Institutions are required to submit Direct Loan and Pell Grant origination records and disbursement records to the COD system. (34 CFR 690.83) Condition The University did not have controls in place to ensure appropriate reporting to COD. Questioned Costs None Identification of How Questioned Costs Were Computed None Context The Unviersity was not performing reconciliations between the student system and COD to ensure appropriate reporting to COD for Pell Grants and Direct Loans. Cause and Effect The College experienced a transition to a new student system. As a result, the control was not operating effectively to prepare and review reconciliations between the new transition to the student system and COD. Recommendation The College should implement procedures and controls to review the amount of Pell Grants and Direct Loans reported to COD to ensure it agrees to what has been disbursed to students. Views of Responsible Officials and Planned Corrective Actions The primary cause of this issue was the significant lack of training and support provided during the implementation of Anthology Student. Similar to the challenges experienced with Return to Title IV (R2T4) processing, University staff did not receive adequate instruction on how to perform Title IV reconciliations within the system or how to extract the data needed to compare internal records with COD. This lack of foundational training made it extremely difficult for staff to understand required reconciliation procedures, identify discrepancies, or troubleshoot system-related issues. In addition, the technical limitations of Anthology Student significantly hindered the University’s ability to perform timely and accurate reconciliations. Anthology Student does not provide a comprehensive or efficient reporting tool that allows users to pull Title IV awarding and disbursement data in a format that aligns with COD records. Staff must manually compile information from multiple system screens and reports, a process that takes several hours and still does not produce a clean, fully reconcilable output. Discussions with other Anthology client institutions confirmed that they are experiencing similar challenges with timely reconciliations due to the system’s reporting limitations. Compounding these reporting challenges, the batch transmission functionality between Anthology Student and COD has been unreliable. Files routinely fail or become “stuck” during transmission, but Anthology offers limited visibility into batch processing status. Until February 2026, the University relied on a system report to identify failed or stalled batches; however, an Anthology system update removed this report and the capability altogether. Without access to this tool, staff have had little ability to monitor or verify successful COD transmission, further complicating reconciliation efforts. Another contributing factor is staffing capacity. The Financial Aid Office has limited personnel, and the extensive time required to manually pull data, consolidate reports, and investigate discrepancies has made it challenging to dedicate the uninterrupted hours required for reconciliation—especially without adequate system training or tools. The University is taking the following steps to address this finding: scheduled reconcilation intervals, staff training and support, and enhanced manual oversight. These actions will remain in place until Anthology Student provides reliable reporting capabilities and complete, consistent training, enabling the University to perform reconciliations accurately and on time.