Finding 32144 (2022-001)

Significant Deficiency

Requirement

Questioned Costs

Year

2022

Accepted

2023-03-30

Audit: 31463

Organization: College of Mount Saint Vincent (NY)

Auditor: Grant Thornton LLP

AI Summary

Core Issue: The College failed to report Direct Loan and Pell Grant disbursements to the COD system within the required 15-day timeframe.
Impacted Requirements: Compliance with Federal Register guidelines and 34 CFR 668.164(a) regarding timely disbursement reporting.
Recommended Follow-up: Review and improve internal controls to ensure all disbursement records are submitted on time.

Finding Text

Finding 2022-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Pursuant to Federal Register Volume 86, Number 119, an institution must submit Pell Grant and Direct Loan 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. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution credits a student?s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 86, Number 119. Of the one hundred three (103) individual Direct Loan disbursements for thirty-three (33) students selected for testing, we noted one (1) record that was not reported within the aforementioned 15-day timeframe. This one (1) Direct Loan record was reported forty-nine (49) days after the actual disbursement date. Of the thirty-two (32) individual Pell Grant disbursements for seventeen (17) students selected for testing, we noted fourteen (14) records that were not reported within the aforementioned 15-day timeframe. These fourteen (14) Pell Grant records were reported between twenty (20) and four hundred forty (440) days after the actual disbursement date. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The College should review the effectiveness of its procedures governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.

Corrective Action Plan

The College reviewed and updated the effectiveness of its procedures governing the reporting of Federal Direct Loan and Pell Grant disbursements to COD no later than 15 days after disbursements to students. The College is reporting the disbursements to COD within the 15-day timeframe to allow for more timely drawdowns of federal funds. Those measures were and continue to be to extract and submit reporting to COD on a minimum weekly basis (with a goal of daily) to remain within the 15-day reporting requirement. Between the 2021-2022 aid years, the College?s Financial Aid department has experienced the leadership transition of three directors, and our current Director is identifying and implementing process refinements to previous steps taken to further improve internal controls. Further, the College has taken steps to both continue and enhance ongoing staff professional development sessions and training. In addition, the College contracted a Financial Aid consultant in the Fall of 2022 for an assessment of our system configurations and processes. The consultant has been retained to undertake a quarterly review of our setups and processes and assist in training the team. In accordance with best practices, Financial Aid?s goal is to continue to eliminate such errors. The findings continue to be addressed.

Other Findings in this Audit

32145 2022-002

Significant Deficiency Repeat
32146 2022-001

Significant Deficiency
32147 2022-002

Significant Deficiency Repeat
608586 2022-001

Significant Deficiency
608587 2022-002

Significant Deficiency Repeat
608588 2022-001

Significant Deficiency
608589 2022-002

Significant Deficiency Repeat

Programs in Audit

ALN	Program Name	Expenditures
84.268	Federal Direct Student Loans	$18.44M
84.063	Federal Pell Grant Program	$5.72M
84.038	Federal Perkins Loan Program	$442,829
84.033	Federal Work-Study Program	$346,258
84.042	Trio_student Support Services	$331,573
84.007	Federal Supplemental Educational Opportunity Grants	$224,284
84.425	Education Stabilization Fund	$220,443
47.076	Education and Human Resources	$165,191
93.364	Nursing Student Loans	$158,943
16.525	Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus	$82,728