Finding 22029 (2022-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-03-12
Audit: 24914
Organization: Marist College and Affiliates (NY)

AI Summary

  • Core Issue: Two Pell Grant disbursements were reported to the COD system 16 days after the disbursement dates, exceeding the 15-day requirement.
  • Impacted Requirements: Compliance with Federal Register Volume 82, Number 122, which mandates timely reporting of disbursement records.
  • Recommended Follow-Up: The College should evaluate and improve its procedures for submitting Pell Grant disbursements to ensure compliance with the 15-day reporting timeframe.

Finding Text

Criteria: Pursuant to Federal Register Volume 82, Number 122, an institution must submit Pell Grant 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. As defined in 34 CFR 668.164(a), the disbursement date is the date that a school credits a student?s account at the school or pays a student or parent borrower directly with Title IV funds received from the U.S. Department of Education or with institutional funds in advance of receiving Title IV program funds. Condition: From a selection of 65 Pell Grant disbursements tested, we identified two disbursements that were reported to the COD system more than 15 days after the respective disbursement dates. Context: Each of the two disbursements were reported to the COD system 16 days after the respective disbursement dates. Cause: Origination records for the 2 students were initially sent on August 31, 2021 and rejected based on pending ISIR transactions not yet processed by CPS. Pell was paid for both students on September 8, 2021. The origination records were resolved and sent to COD on September 24, 2021, 16 days after the Pell paid to the student account. It should be noted that both instances involved a professional judgement review allowing the college to award additional Pell to families. This process can create delays in the process. Effect: Two Pell Grant disbursement were not reported to the COD system within the 15-day timeframe stipulated in Federal Register Volume 82, Number 122. Questioned Costs: None noted. Identified as a Repeat Finding: There was no similar finding in 2021. Recommendation: The College should review the effectiveness of its procedures governing the timely submission of Pell Grant disbursements to the COD system to ensure such records are submitted within the appropriate timeframe. Views of Responsible Officials: We concur. 2021-22 audit indicated that two Pell Grant disbursements were not reported within the 15-day timeframe stipulated in Federal Register Volume 82, Number 122. The origination records were resolved and sent to COD (processing platform) 16 days after Pell paid to the account. Both instances involved a professional judgment review allowing the College to award additional Pell to families. This process can create delays.

Corrective Action Plan

College's Response: We concur. 2021-22 Audit indicated that two Pell Grant disbursements were not reported within the 15-day timeframe stipulated in Federal Register Volume 82, Number 122. The origination records were resolved and sent to COD (processing platform) 16 days after Pell paid to the account. Both instances involved a professional judgment review allowing the college to award additional Pell to families. This process can create delays. Corrective Action Plan: An automated report runs daily to identify disbursement dates 5 days old that have not been acknowledged by the Department of Education. This allows us an additional 10 days to confirm all disbursements are reported and accepted within the 15 day requirement. An additional step has been added to confirm if the origination record is rejected, the Pell record is locked preventing disbursement prior to having an accepted origination record. Responsible Party: Joseph Weglarz, Executive Director, Student Financial Services Proposed Completion Date: January 26, 2023

Categories

Student Financial Aid

Other Findings in this Audit

  • 598471 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $40.66M
84.063 Federal Pell Grant Program $4.17M
84.038 Federal Perkins Loan Program $4.00M
84.047 Trio_upward Bound $729,458
84.033 Federal Work-Study Program $500,000
12.U01 U.s. Army Reserve Officers' Training Corps $430,662
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $273,929
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $250,838
84.042 Trio_student Support Services $248,014
84.007 Federal Supplemental Educational Opportunity Grants $238,975
84.425 Education Stabilization Fund $107,279
93.859 Biomedical Research and Research Training $82,820
93.865 Child Health and Human Development Extramural Research $71,893
47.076 Education and Human Resources $58,654
89.003 National Historical Publications and Records Grants $49,914