Finding 1216304 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-06-01
Audit: 402789
Organization: Adelphi University (NY)
Auditor: GRANT THORNTON

AI Summary

  • Core Issue: The University failed to report three Pell Grant disbursements to the COD system within the required 15-day timeframe, with delays ranging from 56 to 130 days.
  • Impacted Requirements: Institutions must accurately report enrollment and disbursement information to the NSLDS and COD systems to ensure compliance with federal regulations.
  • Recommended Follow-Up: The University should enhance internal controls and monitoring processes for timely reporting of Pell Grant disbursements, transitioning to a fully automated system to reduce errors.

Finding Text

Finding 2025-001 Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Award Year: 2024-2025 Criteria: Under the Federal Pell Grant program, institutions are required to report enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus-Level” and “Program-Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. When a Federal Loan is made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceases to be enrolled on at least a half- time basis or fails to enroll on at least a half-time basis for the period for which the loan is intended, or a student who is enrolled at the institution and who receives a loan under Title IV has changes his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Context: Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant Loan disbursement records to the 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. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution credits a student’s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: During our testing surrounding the University’s COD reporting process, the University did not report all Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 87, Number 105. Of the thirty-two (32) individual Pell Grant disbursements for seventeen (17) students selected for testing, we noted three (3) records that were not reported within the aforementioned 15-day timeframe. These three (3) Pell Grant records were reported between fifty-six (56) and one hundred thirty (130) days after the actual disbursement date. Cause: The condition was due to ineffective controls over the timeliness of COD reporting, including the absence of a formal monitoring process to track and ensure Pell disbursements were reported within required timeframes. In addition, processes and controls were not adequately updated to reflect the Department of Education’s temporary extension of reporting requirements, and late submissions were not timely identified and remediated through supervisory review. Effect: The University did not accurately report enrollment status for three (3) of the students tested within the required timeframe. Questioned Costs: None noted. Identified as a Repeat Finding: No. Recommendation: The University should review the effectiveness of its internal controls governing the timely submission of Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe. Views of Responsible Officials and Planned Corrective Action: Management agrees with the findings and recommendations. The University has implemented corrective actions to prevent recurrence by transitioning Pell Grant processing to a fully automated system that interfaces directly with the COD system. This change is expected to reduce manual intervention, minimize errors, and improve compliance, with completion anticipated within 18 months and ongoing monitoring by Financial Aid and IT.

Corrective Action Plan

We acknowledge the finding and have already implementing corrective actions to ensure it does not occur again. To address this issue the Financial Aid Office will transition Pell Grant processing to a fully automated system that supports direct origination and disbursement. Under this new process, Pell records will be transmitted directly to the U.S. Department of Education through the Common Origination and Disbursement (COD) system. This change will eliminate the need to create and manage files through ED Express and will significantly reduce manual processing, minimize the risk of erroneous originations, and improve overall compliance with federal reporting requirements. The IT and Financial Aid teams will work together on this project plan, with an anticipated completion timeline of 18 months. The Financial Aid Office will continue to monitor the new automated process to ensure accuracy, efficiency, and compliance with the U.S. Department of Education regulations.

Categories

Student Financial Aid Reporting

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $65.91M
84.063 FEDERAL PELL GRANT PROGRAM $12.15M
93.264 NURSE FACULTY LOAN PROGRAM (NFLP) $4.00M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $1.51M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES_PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1.27M
84.033 FEDERAL WORK-STUDY PROGRAM $997,588
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $751,490
84.038 PERKINS LOAN PROGRAM $574,640
93.364 NURSING STUDENT LOANS $528,577
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $505,911
93.376 TITLE: MULTIPLE APPROACHES TO SUPPORT YOUNG BREAST CANCER SURVIVORS AND METASTATIC BREAST CANCER PATIENTS $366,543
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $362,206
93.866 AGING RESEARCH $148,668
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $91,201
47.079 OFFICE OF INTERNATIONAL SCIENCE AND ENGINEERING $85,106
47.074 BIOLOGICAL SCIENCES $81,961
93.242 MENTAL HEALTH RESEARCH GRANTS $67,194
66.437 LONG ISLAND SOUND PROGRAM $63,859
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $25,920
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $25,887
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $21,491
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $20,707
47.050 GEOSCIENCES $19,720
11.478 CENTER FOR SPONSORED COASTAL OCEAN RESEARCH_COASTAL OCEAN PROGRAM $14,572
15.248 NATIONAL LANDSCAPE CONSERVATION SYSTEM $5,923
45.160 PROMOTION OF THE HUMANITIES FELLOWSHIPS AND STIPENDS $1,713