Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to the student accounts within the required time frame and subsequently were paying out any credit balances created on student accounts. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of the student financial aid proceeds and a control in place that allows the financial aid department to know the student financial aid was applied to the student’s account timely. Views of responsible officials and planned corrective action: The College has established formal procedures governing the documentation, approval, and processing of financial aid drawdowns from the Department of Education. A segregated and controlled workflow has been implemented through the use of a secure shared electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. The Financial Aid Office prepares and approves disbursement amounts and communicates them via documented reporting; the Business Office reconciles disbursement amounts to individual student accounts prior to drawdown; the CFO initiates drawdowns after documented review and approval; and the Cashier processes student refunds, where applicable. The documentation is being retained and backed up. Measurable targets will be to do this weekly or as batches are prepared for draw-down. This documentation can be found in the secure shared electronic folder, which has already been implemented. Financial aid disbursements are processed on a weekly or batch basis, and funds are applied to student accounts in compliance with federal requirements, generally within three (3) business days of receipt.