Finding Text
FINDING 2025-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Assistance Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally, per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete the Fiscal Operations Report and Application to Participate (FISAP). Condition During our compliance testing we noted 12 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Additionally, we noted that the College was unable to provide support for amounts included in the FISAP. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 12 students’ disbursement information was submitted between 106 and 114 days late. These were for students during the Summer and Fall semester, there were no late submissions noted for the Sping Semester. However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Additionally, we noted that the College was unable to provide support for amounts included in the FISAP. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of support for the amounts. Thus the College was not in compliance with the reporting requirements. Cause The cause appears to be due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2024-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations. We also recommend retaining documentation to support amounts within the FISAP. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.