Finding 32194 (2022-002)

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

AI Summary

  • Core Issue: Discrepancies between disbursement dates in student records and COD, exceeding the 15-day reporting requirement.
  • Impacted Requirements: Compliance with federal regulations for timely reporting of Pell Grant disbursements.
  • Recommended Follow-Up: Implement weekly checks to align disbursement records between COD and student ledgers.

Finding Text

Finding No. 2022-002 CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping . Criteria According to Federal Register (86 FR 33245) 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. Condition During our disbursement test we found 2 cases out of 60 tested on which the disbursement date on the students? ledger and COD did not match and furthermore, had a discrepancy of more than 15 days. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Effect The Institution could be subject to additional monitoring by the Department as well as penalties and/or safeguards such as letters of credit. Questioned Cost $0 Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursements and trace dates between COD and student?s ledger. 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: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria According to Federal Register (86 FR 33245) 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. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursement and trace dates between COD and student?s ledger. 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. Recommendation from the auditor will be taken and the institution will perform weekly examinations of the disbursements tracing dates between the COD system and the student?s ledger ensuring that all disbursements are correctly posted and that it accurately shows all the activity performed on the COD system.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

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