Finding Text
2025-008 — Financial Reporting– Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2024-007) Federal program information: Funding agencies: U.S. Department of Education Titles: SFA Cluster ALN Number: 84.063 and 84.007 Award years: 2025 Criteria: According to 34 CFR 690.83(b), institutions must report accurate and timely information to the Common Origination and Disbursement (COD) system for each Pell Grant recipient. Required data includes award amounts, disbursement amounts and dates, student personal and enrollment information, verification status, changes in enrollment intensity and withdrawal status, and other pertinent data. Institutions must ensure that student information in their internal systems matches what is reported to COD. Condition: The College did not submit or update disbursement records for students as required. Cause: These reporting issues resulted from insufficient review and reconciliation procedures between the College’s internal system and COD, manual data entry errors, and lack of automated controls for updating and transmitting accurate student data. Additionally, the College has not implemented robust processes for handling student status changes and ensuring all required data elements are properly reported. Effect: Student records reported to COD are not consistently accurate, complete, or up-to-date for Pell Grant recipients. This increases the risk of administrative errors, federal compliance findings, possible questioned costs, and impacts on federal funding and student eligibility. Questioned Costs: None. Context: During our testwork we compared the origination and disbursement records in the College’s records to the COD System, we identified multiple issues indicating inaccurate or incomplete information including discrepancies in the award amounts, disbursement amounts, changes in enrollment differences, and enrollment dates. Recommendation: We recommend that the College enhance its internal controls over COD reporting by implementing regular reconciliations between their information and the COD system, establishing formal procedures to review data for accuracy and completeness prior to transmission, automating relevant data updates where possible, and training staff on reporting requirements and system functionality. Additionally, management should conduct periodic reviews of key COD data fields and student status changes to ensure timely and accurate reporting. Management’s Response: The College concurs with the finding. Management will implement formal procedures to review data and provide additional resources to the Financial Aid department to include training and assistance. Management will implement verification procedures to ensure that amounts reported to COD are accurate, complete, and up to date.