Finding Text
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loans Program (ALN 84.268) and Federal Pell Grant Program (ALN 84.063) Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Significant deficiency Repeat Finding - Yes - 2024-003 Criteria - Institutions submit direct loan and Pell Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. (34 CFR 690.83) Condition - The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Questioned Costs - None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - None Identification of How Questioned Costs Were Computed - None Context - The College did not have appropriate controls in place due to turnover in 2024 over preparing the reconciliation from the College’s records to the COD system. In 2025, the reconciliation was performed monthly; however, they did not have the appropriate segregation of duties over the review of the reconciliation. Cause and Effect - The College experienced turnover in the financial aid department and, throughout the transition, historical procedures and controls were not followed. As a result, the control was not operating effectively to review reconciliations between Banner and COD. Recommendation - The College should implement appropriate review controls over the reconciliation of 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 College will modify its process and update its documented procedures to include an appropriate review of the reconciliation by an individual separate from the process of preparing the reconciliations.