Finding Text
2022 004 Reporting U.S. Department of Education: Student Financial Assistance Cluster ? Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Award Numbers and Years: P063P211813 (7/1/21 ? 6/30/22) and P268K221813 (7/1/21 ? 6/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: N/A Finding Type: Material Weakness Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that the Pell reporting requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University has a process in place to submit the required information to COD on a weekly basis. For the 40 selections we tested, there were no compliance exceptions noted. However, the University did not properly maintain evidence that they had a control in place to review the ED acknowledgement reports and to ensure disbursement data was reported within the 15 calendar day requirement. The University?s policies and procedures to ensure compliance with the above requirements did not include procedures to properly maintain for the existence of a control or that the control was being performed. Cause The University did not have a process in place to maintain the documentation regarding the existence or performance of the control. Effect The University does not meet the Federal requirements to maintain documentation of its internal controls over the 15 calendar day reporting compliance requirement. Questioned Costs None Recommendation We recommend the University ensure that internal controls are in place surrounding the 15 calendar day reporting process related to Pell and Direct Loan reporting in relation to the Student Financial Assistance Cluster and are performed as designed and documentation is maintained.