Finding 1238095 (2025-003)

Material Weakness Repeat Finding
Requirement
ALN
Questioned Costs
-
Year
2025
Accepted
2026-09-29
Audit: 412928
Auditor: KPMG LLP

AI Summary

  • Core Issue: Five out of 60 student records had inaccuracies in key reporting items to the COD system, specifically in Academic End Date and Transaction Number.
  • Impacted Requirements: Compliance with the Uniform Guidance for accurate submission of Direct Loan and Pell Grant records.
  • Recommended Follow-Up: Implement a robust control system to ensure all reported items are complete and accurate, enhancing compliance and accountability.

Finding Text

Federal Program: Student Financial Assistance Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Agency: U.S. Department of Education Pass Through Entity: None Federal Award Year: January 1, 2025 to December 31, 2025 Compliance Requirement: Reporting Criteria Requirement: Per the Uniform Guidance, institutions submit Direct Loan, Pell Grant, and TEACH Grant origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. Key items to test on origination records for the fiscal year are: award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, Academic Start Date, and Academic End Date. Conditions Found: For a sample of 60 students whose records were reported to the COD system, 5 of the 60 students had key items incorrectly reported to the COD. The key items identified as reported incorrectly included Academic End Date and Transaction Number. Cause and Possible Asserted Effect: This resulted in a control failure by the institution to report key items accurately to the COD system. Therefore, this evidenced the lack of an appropriately designed control by the institution to ensure key items are completely and accurately reported to the COD system. Identification of Questioned Costs: There are no questioned costs related to this finding. Sampling: This sample was not intended to be and was not a statistically valid sample. Identification of Repeat Finding: This audit finding is not a repeat finding in the prior year. Recommendation: Our recommendation is for management to design and implement a control in order to ensure the compliance requirement objectives are met. In particular, it is advised to implement a system of control within the institution to ensure key items reported to the COD system are complete and accurate. This will help ensure that there are controls in place to ensure compliance and control ownership is established, thereby preventing or promptly identifying and rectifying instances of noncompliance and ensuring the controls operate as designed. Views of Responsible Officials: The College agrees with the recommendation provided. The College has established a framework of controls and quality assurance testing to ensure complete and accurate reporting to the COD system.

Corrective Action Plan

In response to the deficiencies noted in the audit findings referenced above, management has established a comprehensive framework of inter-departmental controls, routine reconciliations, and independent quality assurance testing. To ensure the absolute accuracy and alignment of records, Financial Aid (FA) and Student Accounts (SA) personnel conduct mandatory monthly reconciliation meetings. During this collaborative process, both departments verify that all federal aid disbursements are properly recorded on the student’s ledger with the correct transactional dates, ensuring perfect alignment with records in the COD system. Supplementing this process, the Financial Aid Office performs independent monthly random spot checks of disbursements directly within the COD system to verify that record dates mirror the actual transaction dates on the student accounts ledger. During these same spot checks, FA personnel validate core academic parameters by cross-referencing student enrollment dates and loan period dates against the official institutional academic calendar, while simultaneously reviewing Cost of Attendance (COA) figures to ensure strict adherence to each student's official award letter. To maintain compliance and reporting during non-standard operational shifts, the Financial Aid Office collaborates immediately with Global Financial Services, our third-party servicer, to update federal records in a timely manner whenever academic dates are modified later than normal. Furthermore, to strengthen institutional data integrity and eliminate enrollment reporting gaps, the Financial Aid Office and the Office of the Registrar participated in joint training sessions focused on National Student Clearinghouse (NSC) and NSLDS reporting mechanics to optimize data transmissions between platforms. As an ongoing monitoring control, the Financial Aid Office now executes an independent monthly random sampling of student records directly from NSLDS. This routine sampling allows management to verify that enrollment statuses are being transmitted accurately and seamlessly from the Clearinghouse to NSLDS

Categories

Student Financial Aid Period of Performance Reporting

Other Findings in this Audit

  • 1238090 2025-001
    Material Weakness Repeat
  • 1238091 2025-002
    Material Weakness Repeat
  • 1238092 2025-003
    Material Weakness Repeat
  • 1238093 2025-001
    Material Weakness Repeat
  • 1238094 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $1.55M
84.063 FEDERAL PELL GRANT PROGRAM $860,631
93.470 ALZHEIMER'S DISEASE PROGRAM INITIATIVE $373,180
93.078 STRENGTHENING EMERGENCY CARE DELIVERY IN THE UNITED STATES HEALTHCARE SYSTEM THROUGH HEALTH INFORMATION AND PROMOTION $151,555
16.528 ENHANCED TRAINING AND SERVICES TO END VIOLENCE AND ABUSE OF WOMEN LATER IN LIFE $148,313
16.582 CRIME VICTIM ASSISTANCE/DISCRETIONARY GRANTS $127,667
93.898 CENTERS FOR DISEASE CONTROL AND PREVENTION INVESTIGATIONS AND TECHNICAL ASSISTANCE $94,000
93.969 GERIATRIC WORKFORCE ENHANCEMENT PROGRAM $84,934
20.941 STRENTHENING MOBILITY AND REVOLUTIONIZING TRANSPORTATION (SMART) GRANTS PROGRAM $76,889