Finding 1201539 (2025-004)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396098
Organization: Drexel University (PA)

AI Summary

  • Core Issue: One student disbursement was reported 20 days late to the COD, violating the 15-day reporting requirement.
  • Impacted Requirements: Timely reporting of federal student disbursements is essential for compliance and tracking.
  • Recommended Follow-Up: Implement a checklist process to ensure disbursements are reported promptly and errors are identified quickly.

Finding Text

Criteria Student disbursements are required to be reported in the COD system within 15 days of disbursing the federal funds to the student. Condition Drexel University acquired Salus University at the end of FY2024. Given the separate control environments in place during FY2025, each University was treated as a separate population for testing. We examined 25 student records for each University. Through our testing of 25 selections for Drexel University, we noted that one of the 25 selections was not reported to the COD within 15 calendar days of the disbursement to the student. The noted disbursement was reported 20 calendar days late. Cause This exception was caused due to the student not answering a question on the Free Application for Federal Student Aid (FAFSA) regarding the completion of high school status, which relates to Ability to Benefit (ATB) eligibility. As the question was unanswered, the Banner system used for student accounts was not able to timely report disbursements to the COD. Effect Disbursements to the selected student were not reported timely to the COD. Additionally, late reporting could cause issues in tracking of disbursements made to students. Questioned Costs None noted. Recommendation We recommend the University establish a process, such as a checklist to report disbursements on a more frequent basis to the COD, to ensure timely transmission and error identification within the disbursement reporting. Management’s Views and Corrective Action Plan Following these findings are management’s views and corrective action plan.

Corrective Action Plan

Management agrees with this finding. The instance in which a Pell Grant disbursement was not reported to the U.S. Department of Education Common Origination and Disbursement (COD) System within the required 15 calendar days was due to the student not answering the high school completion question on the Free Application for Federal Student Aid (FAFSA), which relates to Ability to Benefit (ATB) eligibility. To address this issue and prevent recurrence, we have implemented an additional control. We now identify students who have been awarded a Pell Grant but have not answered the FAFSA high school completion question. For these students, an ATB requirement is posted on RRAAREQ, which prevents the Pell Grant from disbursing until the FAFSA question has been resolved. This process change ensures that Pell Grant funds will not disburse until the FAFSA high school completion question is completed, allowing the Pell Grant record to successfully extract to COD within the required reporting timeframe. This system update corrects the condition identified in the audit finding and strengthens our internal controls to ensure compliance with federal reporting requirements.

Categories

Reporting Eligibility

Other Findings in this Audit

  • 1201519 2025-001
    Material Weakness Repeat
  • 1201520 2025-001
    Material Weakness Repeat
  • 1201521 2025-001
    Material Weakness Repeat
  • 1201522 2025-001
    Material Weakness Repeat
  • 1201523 2025-001
    Material Weakness Repeat
  • 1201524 2025-001
    Material Weakness Repeat
  • 1201525 2025-001
    Material Weakness Repeat
  • 1201526 2025-001
    Material Weakness Repeat
  • 1201527 2025-002
    Material Weakness Repeat
  • 1201528 2025-002
    Material Weakness Repeat
  • 1201529 2025-002
    Material Weakness Repeat
  • 1201530 2025-002
    Material Weakness Repeat
  • 1201531 2025-002
    Material Weakness Repeat
  • 1201532 2025-002
    Material Weakness Repeat
  • 1201533 2025-002
    Material Weakness Repeat
  • 1201534 2025-002
    Material Weakness Repeat
  • 1201535 2025-003
    Material Weakness Repeat
  • 1201536 2025-003
    Material Weakness Repeat
  • 1201537 2025-004
    Material Weakness Repeat
  • 1201538 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $273.32M
84.063 FEDERAL PELL GRANT PROGRAM $25.96M
93.342 HEALTH PROFESSIONS STUDENT LOANS, INCLUDING PRIMARY CARE LOANS AND LOANS FOR DISADVANTAGED STUDENTS $8.74M
93.310 Trans-NIH Research Support $4.30M
12.431 Basic Scientific Research $4.29M
84.033 FEDERAL WORK-STUDY PROGRAM $2.56M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $2.44M
93.396 Cancer Biology Research $1.51M
12.420 Military Medical Research and Development $1.28M
12.910 Research and Technology Development $1.25M
93.351 Research Infrastructure Programs $1.20M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $978,753
12.300 Basic and Applied Scientific Research $922,561
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease $740,729
94.026 AMERICORPS NATIONAL SERVICE AND CIVIC ENGAGEMENT RESEARCH COMPETITION 94.026 $721,469
20.205 Highway Planning and Construction $574,863
93.989 International Research and Research Training $540,306
97.151 Fire Prevention & Safety $473,530
93.732 Mental and Behavioral Health Education and Training Grants $452,822
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $451,572
84.200 Graduate Assistance in Areas of National Need $429,220
20.109 Air Transportation Centers of Excellence $415,314
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $380,384
12.630 Basic, Applied, and Advanced Research in Science and Engineering $364,728
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $358,495
93.877 Autism Collaboration, Accountability, Research, Education, and Support $354,410
17.259 WIOA Youth Activities $314,801
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $286,250
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $280,075
93.217 Family Planning Services $254,996
47.070 Computer and Information Science and Engineering $238,866
93.213 Research and Training in Complementary and Integrative Health $230,789
66.047 Hydrofluorocarbon Reclaim and Innovative Destruction Grants $221,176
45.301 Museums for America $218,707
93.575 Child Care and Development Block Grant $195,942
43.099 Science $195,571
11.008 NOAA Mission-Related Education Awards $189,884
93.433 ACL National Institute on Disability, Independent Living, and Rehabilitation Research $184,073
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $182,656
16.566 NATIONAL INSTITUTE OF JUSTICE W.E.B. DUBOIS FELLOWSHIP PROGRAM $181,184
93.350 National Center for Advancing Translational Sciences $171,000
93.226 Research on Healthcare Costs, Quality and Outcomes $158,479
16.839 STOP School Violence $156,992
10.310 Agriculture and Food Research Initiative (AFRI) $148,169
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $140,413
47.050 Geosciences $139,281
81.049 Office of Science Financial Assistance Program $133,371
93.136 Injury Prevention and Control Research and State and Community Based Programs $117,832
47.078 Polar Programs $117,194
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $113,250
81.086 Conservation Research and Development $111,613
47.079 Office of International Science and Engineering $109,629
64.054 Research and Development $106,905
81.214 Environmental Monitoring/Cleanup, Cultural and Resource Mgmt., Emergency Response Research, Outreach, Technical Analysis $106,028
11.431 Climate and Atmospheric Research $103,149
93.516 Public Health Training Centers Program $102,474
84.129 Rehabilitation Long-Term Training $98,854
20.RD N/A $93,415
93.121 Oral Diseases and Disorders Research $92,776
10.RD N/A $92,084
47.075 Social, Behavioral, and Economic Sciences $88,893
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $84,950
10.025 Plant and Animal Disease, Pest Control, and Animal Care $82,808
84.120 Minority Science and Engineering Improvement $82,466
94.006 AMERICORPS NATIONAL SERVICE AND CIVIC ENGAGEMENT RESEARCH COMPETITION 94.026 $81,637
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $80,263
89.003 NATIONAL HISTORICAL PUBLICATIONS AND RECORDS GRANTS $77,083
12.750 Uniformed Services University Medical Research Projects $75,946
15.670 Adaptive Science $74,351
81.087 Renewable Energy Research and Development $73,899
93.917 HIV Care Formula Grants $73,547
98.001 USAID Foreign Assistance for Programs Overseas $72,487
11.417 Sea Grant Support $71,769
20.108 Aviation Research Grants $69,424
81.999 N/A $69,151
11.307 Economic Adjustment Assistance $67,284
93.914 HIV Emergency Relief Project Grants $66,418
93.307 Minority Health and Health Disparities Research $60,251
45.024 Promotion of the Arts Grants to Organizations and Individuals $57,009
93.855 Allergy and Infectious Diseases Research $56,871
16.548 Delinquency Prevention Program $55,790
97.044 Assistance to Firefighters Grant $54,327
93.879 Medical Library Assistance $53,860
16.575 Crime Victim Assistance $53,677
19.009 Academic Exchange Programs - Undergraduate Programs $50,304
93.172 Human Genome Research $48,740
45.163 Promotion of the Humanities Professional Development $46,872
19.400 Academic Exchange Programs - Graduate Students $45,457
47.084 NSF Technology, Innovation, and Partnerships $40,592
20.200 Highway Research and Development Program $40,390
93.686 Ending the HIV Epidemic: A Plan for America — Ryan White HIV/AIDS Program Parts A and B $40,301
93.273 Alcohol Research Programs $39,698
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $38,821
93.940 HIV Prevention Activities Health Department Based $38,658
21.015 Resources and Ecosystems Sustainability, Tourist Opportunities, and Revived Economies of the Gulf Coast States $38,576
93.397 Cancer Centers Support Grants $36,970
93.279 Drug Use and Addiction Research Programs $36,859
11.420 Coastal Zone Management Estuarine Research Reserves $35,996
93.395 Cancer Treatment Research $35,285
43.001 N/A $35,030
45.313 Laura Bush 21st Century Librarian Program $34,504
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $34,333
47.076 STEM Education (formerly Education and Human Resources) $33,208
21.029 Coronavirus Capital Projects Fund $32,953
16.838 Comprehensive Opioid, Stimulant, and other Substances Use Program $32,871
47.074 Biological Sciences $31,768
93.837 Cardiovascular Diseases Research $31,331
93.999 #N/A $30,000
45.312 National Leadership Grants $28,825
84.425 Education Stabilization Fund $26,465
12.RD N/A $25,481
93.113 Environmental Health $25,000
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $24,796
93.242 Mental Health Research Grants $23,166
93.426 The National Cardiovascular Health Program $22,497
93.999 N/A $21,140
93.859 Biomedical Research and Research Training $20,876
15.RD N/A $20,241
66.436 SURVEYS, STUDIES, INVESTIGATIONS, DEMONSTRATIONS, AND TRAINING GRANTS AND COOPERATIVE AGREEMENTS - SECTION 104(B)(3) OF THE CLEAN WATER ACT $19,871
66.509 Science To Achieve Results (STAR) Research Program $19,081
66.511 Office of Research and Development Consolidated Research/Training/Fellowships $18,520
66.466 Geographic Programs - Chesapeake Bay Program $17,865
11.609 Measurement and Engineering Research and Standards $15,884
93.361 Nursing Research $15,734
12.800 Air Force Defense Research Sciences Program $15,000
66.203 Environmental Finance Center Grants $14,771
93.866 Aging Research $14,630
47.049 Mathematical and Physical Sciences $14,527
66.999 N/A $14,337
43.001 Science $13,731
84.015 National Resource Centers Program for Foreign Language and Area Studies or Foreign Language and International Studies Program and Foreign Language and Area Studies Fellowship Program $13,248
16.817 Byrne Criminal Justice Innovation Program $12,294
43.008 Office of Stem Engagement (OSTEM) $12,054
93.110 Maternal and Child Health Federal Consolidated Programs $10,556
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $8,883
84.022 OVERSEAS PROGRAMS - DOCTORAL DISSERTATION RESEARCH ABROAD $8,169
66.436 Surveys, Studies, Investigations, Demonstrations, and Training Grants and Cooperative Agreements - Section 104(b)(3) of the Clean Water Act $8,114
15.962 National Wild and Scenic Rivers System $7,561
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $6,976
45.032 21st Century Museum Professional Program $6,428
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $5,586
15.945 Cooperative Research and Training Programs – Resources of the National Park System $5,489
93.838 Lung Diseases Research $5,141
66.456 National Estuary Program $5,090
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $5,000
93.399 Cancer Control $4,119
10.464 Socially Disadvantaged Farmers and Ranchers Policy Research Center $3,711
66.306 Environmental Justice Collaborative Problem-Solving Cooperative Agreement Program $3,708
93.867 Vision Research $2,733
45.149 Promotion of the Humanities Division of Preservation and Access $1,857
20.215 HIGHWAY TRAINING AND EDUCATION $1,812
66.461 Regional Wetland Program Development Grants $1,709
93.270 Viral Hepatitis Prevention and Control $1,120
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $-364
81.135 Advanced Research Projects Agency - Energy $-673
47.041 Engineering $-707
93.865 Child Health and Human Development Extramural Research $-877
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $-1,612
93.994 Maternal and Child Health Services Block Grant to the States $-1,766
93.173 Research Related to Deafness and Communication Disorders $-8,688
14.U01 N/A $-9,311
93.959 Block Grants for Prevention and Treatment of Substance Abuse $-18,089
93.998 Autism and Other Developmental Disabilities, Surveillance, Research, and Prevention $-60,650
93.982 Mental Health Disaster Assistance and Emergency Mental Health $-72,360