Finding Text
Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Common Origination and Disbursement (COD) reporting, we noted one instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we noted, one Pell disbursement was not reported within the required 15 days. Cause: The College did not have proper control or procedures in place to verify disbursements were reported to COD within the required 15 days after disbursement. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.