Finding 1241793 (2024-012)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2026-11-06
Audit: 415778
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: The College is not accurately reporting student award amounts and costs of attendance in the COD system.
  • Impacted Requirements: Failure to comply with federal reporting requirements for the Federal Pell Grant Program.
  • Recommended Follow-Up: Implement policies for systematic review and updates of origination records before submission to ensure compliance.

Finding Text

Finding No.: 2024-012 - Reporting Identification of the federal program: Federal Agency: U.S. Department of Education AL No. and Title: 84.063 Federal Pell Grant Program Federal Award No.: P063Q194572, P063Q204572, P063Q214572, P063Q224572, P063Q234572, P063P224572, P063P234572, P063P244572 Criteria or specific requirement (including statutory, regulatory or other citation): The College is required to submit origination records and disbursement records to the Common Origination and Disbursement (COD) system. Key items on origination records, if applicable, are award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Key items on disbursement records are disbursement date and amount. Conditions: 1. Student’s annual award amount reported in the Origination records does not agree with the annual award amount based on the “Disbursement Schedule for Determining Annual Awards” published by ED. 2. Student’s cost of attendance reported in the Origination records pertains to the cost of attendance for full-time students, even if the student’s enrollment status is three-quarters time, half time or less-than-half time. Cause: The College lacks adequate internal control policies and procedures over compliance with applicable federal regulations related to reporting, specifically, the systematic review and updating of student’s origination records in COD system. Effect or potential effect: The College is in noncompliance with applicable reporting requirements. Questioned costs: Not applicable. No questioned cost is presented as the non-compliance was related to reporting requirements. Context: We identified 3,315 COD origination and disbursements records reported to the COD system during the year. We tested 60 records. The samples were statistically valid. For 9 (or 15%) origination records tested, student’s annual award amount reported does not agree with the annual award amount based on the “Disbursement Schedule for Determining Annual Awards” published by ED. For 18 (or 30%) origination records tested, student’s cost of attendance reported in the Origination records pertains to the cost of attendance for full-time students, even if the student’s enrollment status is three-quarters time, half time or less-than-half time. Identification as a repeat finding, if applicable: 2023-014 Recommendation: College management should establish policies and procedures over reporting requirements, specifically, requiring a systematic process for reviewing and updating the student’s origination records prior to and/or after submission to COD system. Views of responsible officials: The College agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

The College acknowledges the finding and has strengthened its internal controls over federal reporting by piloting the new Jenzabar Financial Aid (JFA) system during SY 2024–2025. The system is designed to reduce manual processing and minimize errors previously encountered in reporting student award amounts, cost of attendance, and disbursement records. JFA, together with SONIS, will improve the accuracy of student information, streamline the review and updating of COD records, and strengthen compliance with federal reporting requirements.

Categories

Student Financial Aid Period of Performance Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1241786 2024-005
    Material Weakness Repeat
  • 1241787 2024-006
    Material Weakness Repeat
  • 1241788 2024-007
    Material Weakness Repeat
  • 1241789 2024-008
    Material Weakness Repeat
  • 1241790 2024-009
    Material Weakness Repeat
  • 1241791 2024-010
    Material Weakness Repeat
  • 1241792 2024-011
    Material Weakness Repeat
  • 1241794 2024-013
    Material Weakness Repeat
  • 1241795 2024-014
    Material Weakness Repeat
  • 1241796 2024-015
    Material Weakness Repeat
  • 1241797 2024-016
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $7.42M
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $2.20M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $721,598
84.047 TRIO UPWARD BOUND $237,825
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $26,277
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $12,552
84.425 EDUCATION STABILIZATION FUND $2,100