Finding 1240502 (2026-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2026
Accepted
2026-10-15
Audit: 414960
Auditor: KPMG LLP

AI Summary

  • Core Issue: The University failed to report Federal Pell Grant disbursements to the COD system within the required 15-day timeframe, leading to noncompliance with federal regulations.
  • Impacted Requirements: The failure relates to the reporting criteria outlined in the Federal Register and 2 CFR § 200.303, which mandate timely reporting and effective internal controls over federal awards.
  • Recommended Follow-Up: Enhance monitoring processes to ensure compliance with federal reporting requirements for Pell Grant disbursements and prevent future misinterpretations of guidance.

Finding Text

Finding 2026-002 – Reporting Federal Program: Student Financial Assistance Cluster Listing Number: 84.063 Federal Pell Grant Program Federal Agency: Department of Education Award Year: June 1, 2025 – May 31, 2026 Criteria: According to the Federal Register Vol. 89 No. 181, for institutions beginning their fiscal years prior to 7/1/2025, an institution must submit Pell Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement, whichever is later. Additionally, 2 CFR § 200.303 requires the recipient of federal funds to establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and Context: The University did not have effective internal controls over the review of Federal Pell Grant disbursements and did not report Pell Grant program data to the Common Origination and Disbursements (COD) system within the required timeframes. During our testwork of 40 Federal Pell Grant student disbursements totaling $122,977, we identified 18 disbursements for 18 students, totaling $47,002, that were not reported to the COD system within the required 15-day reporting period. The disbursements were made between August 25, 2025, and August 26, 2025, and were reported to COD 17 to 18 days after the disbursement dates. Upon further review, the University determined that Pell Grant program data for an additional 1,729 student disbursements was not reported to COD within the required timeframe during the fiscal year. Further, we noted the University did not have adequate review or monitoring controls in place to ensure that Pell disbursement data was reported to COD within the required timeframes. Possible Cause and Effect: The late reporting to COD was caused by insufficient monitoring over the application of federal reporting requirements for Pell Grant disbursements. University officials determined that the disbursements were not reported within the required 15-day timeframe because officials misinterpreted Electronic Announcement ID GENERAL-24-94 issued on July 30, 2024, which allowed certain Pell Grant disbursement records for the 2024-2025 award year to be submitted to COD no later than November 30, 2024. This guidance wasincorrectly applied to the 2025-2026 award year. While the University has procedures in place to report Pell Grant disbursements to COD timely, the related monitoring controls did not identify that the reporting requirements had been misapplied. As a result, the Pell Grant disbursements were reported to COD after the required deadline, resulting in noncompliance with federal reporting requirements. Isolated or Systemic: Systemic. Questioned Costs: None noted. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the University enhances its monitoring over the application of federal reporting requirements for Pell Grant disbursements to ensure all Pell disbursements are reported to COD within the required timeframe. View of Responsible Officials: Management concurs with the finding. The University acknowledges that Pell Grant disbursements were not reported to the Common Origination and Disbursement (COD) system within the required 15-day timeframe during a portion of the 2025-26 award year. The University determined that the late reporting resulted from the continued application of Department of Education guidance that had provided extended reporting flexibility in response to FAFSA processing issues. That flexibility applied to the 2024-25 award year and did not extend to the 2025-26 award year. While the University had a process for monitoring federal guidance, the process did not sufficiently identify that the temporary reporting flexibility had expired or ensure that the standard 15-day reporting requirement was applied for the 2025-26 award year. The University was unable to determine precisely where the communication breakdown occurred.

Corrective Action Plan

Finding #2026-002 Context Finding #2026-02 indicates the University did not have effective internal controls over the review of Federal Pell Grant disbursements and did not report Pell Grant program data to the Common Origination and Disbursements (COD) system within the required timeframes. 1. Weekly Monitoring of Pell Disbursement Reporting Beginning with the 2026-27 academic year, the Grants and Scholarships Specialist will perform a weekly reconciliation at the beginning of each week to confirm that Pell Grant disbursements are being reported to COD within the required 15-calendar-day reporting period. The review will reconcile the applicable Pell disbursement activity against the corresponding COD reporting activity and identify any disbursements that have not been reported within the required timeframe. This control is intended to provide an ongoing, timely review of Pell reporting compliance rather than relying solely on the underlying automated reporting process. 2. Exception Review and Resolution The Grants and Scholarships Specialist will investigate all exceptions identified through the weekly reconciliation. Each exception will be documented, including the nature of the exception and the corrective action taken. The Specialist will ensure that identified records are reported to COD before the next reporting cycle, as appropriate. This process will provide a documented exception-management process and establish clear responsibility for resolving reporting discrepancies. To strengthen documentation and traceability going forward, we will implement the following measures: Retain all reconciliation reports on a shared drive, organized by date and year, to maintain a clear historical record of each weekly cycle. A column will be added to each report capturing the resolution finding for every identified discrepancy. A comment will be added to each affected student's Financial Aid status page in PeopleSoft (PS) documenting the resolution. 3. Monitoring of Federal and State Regulatory Changes The Assistant Director of Compliance is responsible for monitoring federal and state regulatory changes affecting financial aid programs and for evaluating changes that may affect University policies, procedures, and reporting requirements. The Assistant Director of Compliance will update the Financial Aid Office’s policy and procedure manual as necessary and will communicate applicable regulatory changes to the areas affected by those changes. Attention will be given to temporary guidance, waivers, extensions, and other regulatory provisions that have defined award-year applicability or expiration dates. 4. Management Review of Regulatory Changes To provide an additional level of oversight, the Assistant Director of Compliance will bring regulatory changes to the Financial Aid management team for review prior to implementation. The management review will provide an opportunity to confirm the applicability of new or revised guidance to the appropriate award year and to ensure that temporary provisions or reporting extensions are not inadvertently carried forward after their expiration. This additional review is intended to strengthen the University’s internal control over the interpretation and implementation of federal reporting requirements. Expected Outcome The combination of weekly Pell reporting reconciliation, documented exception management, designated responsibility for monitoring regulatory changes, and management review of significant regulatory changes is designed to provide reasonable assurance that Pell Grant disbursements are reported to COD within the required 15-calendar-day timeframe. These controls also strengthen the University’s process for identifying changes in federal guidance and ensuring that temporary or award-year-specific provisions are appropriately applied and discontinued when no longer applicable. Responsible Parties Chauncey Piazza, Assistant Director Christopher Shane, Grants and Scholarships Specialist

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring

Other Findings in this Audit

  • 1240503 2026-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $115.38M
84.063 FEDERAL PELL GRANT PROGRAM $11.22M
84.033 FEDERAL WORK-STUDY PROGRAM $2.12M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $1.60M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $664,144
93.847 DIABETES, DIGESTIVE, AND KIDNEY DISEASES EXTRAMURAL RESEARCH $390,076
93.867 VISION RESEARCH $341,468
93.866 AGING RESEARCH $222,431
93.838 LUNG DISEASES RESEARCH $171,871
47.074 BIOLOGICAL SCIENCES $166,316
93.310 TRANS-NIH RESEARCH SUPPORT $137,677
47.079 INTERNATIONAL SCIENCE AND ENGINEERING $137,216
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $134,699
10.001 AGRICULTURAL RESEARCH BASIC AND APPLIED RESEARCH $128,705
12.800 AIR FORCE DEFENSE RESEARCH SCIENCES PROGRAM $117,376
21.008 LOW INCOME TAXPAYER CLINICS $116,120
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $99,587
43.001 SCIENCE $99,565
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $85,025
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $84,833
10.176 DAIRY BUSINESS INNOVATION INITIATIVES $81,730
12.910 RESEARCH AND TECHNOLOGY DEVELOPMENT $65,589
47.050 GEOSCIENCES $63,434
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $61,456
43.012 SPACE TECHNOLOGY $60,781
11.609 MEASUREMENT AND ENGINEERING RESEARCH AND STANDARDS $59,779
12.630 BASIC, APPLIED, AND ADVANCED RESEARCH IN SCIENCE AND ENGINEERING $59,514
10.210 HIGHER EDUCATION NATIONAL NEEDS GRADUATE FELLOWSHIP GRANTS $50,980
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $50,450
93.226 RESEARCH ON HEALTHCARE COSTS, QUALITY AND OUTCOMES $41,660
93.853 EXTRAMURAL RESEARCH PROGRAMS IN THE NEUROSCIENCES AND NEUROLOGICAL DISORDERS $27,753
97.061 CENTERS FOR HOMELAND SECURITY $23,220
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $19,678
84.325 SPECIAL EDUCATION - PERSONNEL DEVELOPMENT TO IMPROVE SERVICES AND RESULTS FOR CHILDREN WITH DISABILITIES $17,456
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $16,503
45.024 PROMOTION OF THE ARTS GRANTS TO ORGANIZATIONS AND INDIVIDUALS $16,418
93.399 CANCER CONTROL $16,201
47.041 ENGINEERING $15,250
11.417 SEA GRANT SUPPORT $14,809
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $14,554
93.395 CANCER TREATMENT RESEARCH $13,762
47.083 INTEGRATIVE ACTIVITIES $13,449
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $11,070
93.837 CARDIOVASCULAR DISEASES RESEARCH $7,433
12.750 UNIFORMED SERVICES UNIVERSITY MEDICAL RESEARCH PROJECTS $6,895
93.839 BLOOD DISEASES AND RESOURCES RESEARCH $6,775
93.396 CANCER BIOLOGY RESEARCH $6,114
93.213 RESEARCH AND TRAINING IN COMPLEMENTARY AND INTEGRATIVE HEALTH $4,987
93.RD Strong Heart Study (SHS) - Creative Sovereignty Lab $4,605
10.699 PARTNERSHIP AGREEMENTS $4,283
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $3,627
45.025 PROMOTION OF THE ARTS PARTNERSHIP AGREEMENTS $2,740
93.879 MEDICAL LIBRARY ASSISTANCE $1,166
12.431 BASIC SCIENTIFIC RESEARCH $21