Finding 32193 (2022-001)

-
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2023-06-29

AI Summary

  • Core Issue: A discrepancy was found between the disbursements reported to COD and the student’s ledger, leading to an over-award situation.
  • Impacted Requirements: The institution failed to comply with the requirement to report disbursements accurately within 15 days, as outlined in 34 CFR 668.164.
  • Recommended Follow-Up: Strengthen disbursement control procedures to ensure accurate posting and matching of amounts between COD and student ledgers.

Finding Text

Finding No. 2022-001 CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate recordkeeping . Criteria According to 34 CFR 668.164 an institution must disburse during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student's parent, is eligible to receive for that payment period. Condition During our disbursement test we found 1 case out of 60 tested on which the student?s COD listed two disbursements on June 13, 2022, one for $2,435.00 and another for $3,247.50, but on the student?s ledger only one disbursement was listed for $2,435.00. The student was eligible to receive the $2,435, but not the $3,247.50. Cause Both disbursements were made on the same date; however, inadvertently the correct steps were not performed in ED Express in order for the return to be processed. Effect The Institution must return the amount of over award and could be subject to additional monitoring by the Department as well as penalties and/or safeguards such as letters of credit. Questioned Cost $3,247.50 Recommendation The Institution must reinforce disbursement control procedures to ensure that all disbursements are correctly posted and the amounts between COD and student?s ledger are a match. Management Response and Corrective Action Plan See Corrective Action Plan for Management?s response

Corrective Action Plan

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-001: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate recordkeeping Criteria According to 34 CFR 668.164 an institution must disburse during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student?s parent, is eligible to receive for that payment period. Cause Both disbursements were made on the same date; however, inadvertently the correct steps were not performed in ED Express in order for the return to be processed. Recommendation The Institution must reinforce disbursement control procedures to ensure that all disbursements are correctly posted and the amounts between COD and student?s ledger are a match. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. The monthly evaluation, verification and reconciliation will include an internal audit performed by another office responsible for comparing the COD system with the student ledger to reinforce the actual disbursement control procedures ensuring that all disbursements are correctly posted and that the student?s ledger correctly shows all the activity performed on the COD system. The institution already refunded the questioned cost of $3,247.50

Categories

Questioned Costs Student Financial Aid Subrecipient Monitoring Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.54M
84.425 Education Stabilization Fund $196,163
84.007 Federal Supplemental Educational Opportunity Grants $73,281
84.033 Federal Work-Study Program $44,909