FAC Explorer

Finding 2255 (2023-001)

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Requirement
L
Questioned Costs
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Year
2023
Accepted
2023-11-21
Audit: 3911
Organization: Vermont State Colleges (VT)
Auditor: Withumsmith+brown PC

AI Summary

  • Core Issue: Colleges failed to report Pell Grant and Direct Loan disbursements to the COD within the required 15-day timeframe for 3 out of 40 students.
  • Impacted Requirements: Compliance with 34 CFR 690.83(b) and Federal Register guidelines for timely reporting of financial aid disbursements.
  • Recommended Follow-Up: Management should review and update reporting policies and procedures to ensure compliance with the 15-day reporting requirement.

Finding Text

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service 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. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $26.17M
84.063 Federal Pell Grant Program $13.10M
84.042 Trio_student Support Services $1.50M
84.047 Trio_upward Bound $1.31M
93.575 Child Care and Development Block Grant $1.30M
84.033 Federal Work-Study Program $1.27M
59.077 Community Navigator Pilot Program $1.16M
84.007 Federal Supplemental Educational Opportunity Grants $1.11M
59.037 Small Business Development Centers $1.01M
90.601 Northern Border Regional Development $810,690
84.031 Higher Education_institutional Aid $797,633
84.116 Fund for the Improvement of Postsecondary Education $333,171
84.425 Education Stabilization Fund $329,611
94.006 Americorps $308,447
84.048 Career and Technical Education -- Basic Grants to States $292,268
84.217 Trio_mcnair Post-Baccalaureate Achievement $246,016
21.027 Coronavirus State and Local Fiscal Recovery Funds $238,154
16.753 Congressionally Recommended Awards $224,446
93.236 Grants to States to Support Oral Health Workforce Activities $210,251
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $175,896
17.285 Apprenticeship USA Grants $169,186
93.859 Biomedical Research and Research Training $150,474
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $146,104
47.073 National Science Foundation/uvm/ns $123,509
93.959 Block Grants for Prevention and Treatment of Substance Abuse $90,548
93.778 Medical Assistance Program $77,868
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $75,721
11.611 Manufacturing Extension Partnership $67,504
93.958 Block Grants for Community Mental Health Services $64,295
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $62,000
59.059 Congressional Community Project $58,847
47.050 Geosciences $52,669
20.205 Highway Planning and Construction $48,093
93.855 Allergy, Immunology and Transplantation Research $47,906
11.307 Economic Adjustment Assistance $41,778
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $38,305
84.181 Special Education-Grants for Infants and Families $33,910
10.575 Farm to School Grant Program $20,408
17.720 Disability Employment Policy Development $19,364
10.500 Cooperative Extension Service $17,899
43.001 Science $7,008
93.434 Every Student Succeeds Act/preschool Development Grants $7,000
45.025 Promotion of the Arts_partnership Agreements $3,122
11.467 Meteorologic and Hydrologic Modernization Development $1,066
93.888 Specially Selected Health Projects $944