Finding Text
BRIGHAM YOUNG UNIVERSITY-HAWAII SCHEDULE OF FINDINGS AND QUESTIONED COSTS for the year ended December 31, 2025 Section III – Federal Award Findings and Questioned Costs Finding 2025-002 – Untimely Reporting of Disbursement Records Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award Title: Federal Pell Grant Program Award Years: 7/2024 – 6/2026 Criteria Federal Register Volume 86, Issue 119 (June 24, 2021) – 86 FR 33246: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to the U.S. Department of Education’s Common Origination and Disbursement (COD) system, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Condition Of the population of students who were disbursed Federal Pell Grants and/or Direct Loans during the period January 1, 2025 through December 31, 2025, 25 students were selected to validate that the disbursement information was timely and accurately submitted to the U.S. Department of Education’s (ED) Common Origination and Disbursement (COD) system within 15 days of funds being disbursed to the student. Of the 25 students selected, three instances were noted in January 2025 in which disbursement information was not reported to the COD system within 15 days. The disbursement information was reported 35 days after the disbursement occurred. Cause For the three instances that occurred in January 2025, the Financial Aid Senior Manager involved in timely reporting of disbursements as the primary control owner was unavailable and there was no back-up individual who was trained to ensure timely reporting of disbursements. Effect Brigham Young University-Hawaii's (the University) failure to submit disbursement records within the required timeframe may result in the Department of Education rejecting all or part of the reported disbursement and/or additional adverse actions in accordance with 34 CFR 668. Questioned Costs None. Repeat Finding in the Prior Year No. Recommendation We recommend that the University train additional personnel to perform the relevant COD disbursement controls to ensure that back-up individual(s) are in place to perform the necessary procedures to ensure timely and accurate reporting as part of the COD reporting process. Management’s Views and Corrective Action Plan Management’s response is reported in management’s views and corrective action plan included at the end of this report.