Finding Text
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Federal Award Numbers: P063P242023, P268K252023; Award Year: 2025 Criteria: Per 34 CFR §668.164(a) and related Department of Education guidance, institutions are required to submit accurate disbursement records for Federal student aid programs to the Common Origination and Disbursement (COD) system within 15 calendar days of the disbursement date or becoming aware of the need to adjust a disbursement. Additionally, per 34 CFR §668.16(b) and 34 CFR §673.3, institutions are required to establish and maintain administrative and fiscal procedures to ensure proper and accurate reporting of Title IV program activity, including the accurate preparation and submission of the Fiscal Operations Report and Application to Participate (FISAP). Condition: During our testing of reporting compliance, we identified the following: 1. COD Reporting: For 2 of 37 Federal Direct Loan awards tested, the student's aid year and/or cost of attendance was incorrectly reported to COD. 17 of 17 Pell Grant fall disbursements tested were not reported to COD within the required 15-day period. 2 of 37 Federal Direct Loan disbursements tested were not reported within the required timeframe. The sample was not intended to be, and was not, a statistically valid sample. 2. FISAP Reporting: The FISAP was not initially prepared and submitted accurately, resulting in the need for subsequent correction. In addition, management was unable to provide supporting documentation for various information that was reported in the FISAP. Cause: Turnover within the financial aid department during the period resulted in a lack of continuity in established reporting processes. Effect: Failure to report disbursement data timely to COD and to accurately prepare and submit the FISAP may result in noncompliance with federal requirements and may affect the reliability of information reported to the U.S. Department of Education. Questioned Costs: None reported Context: The exceptions identified above represent deviations from federal reporting requirements across both real-time (COD) and periodic (FISAP) reporting processes within the Student Financial Assistance Cluster. Repeat Finding: Yes Recommendations: The University should evaluate its processes and controls to ensure reporting is completed accurately and timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.