Finding 369982 (2023-003)

2023-003; Federal Agency: U.S Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.063; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance Requirement: Reporting; Finding Type: Significant Deficiency; Criteria: As described in 34 CFR Section 690.83, all schools receiving Pell grant must submit Pell payment data to the Department through the Common Origination and Disbursement (COD) System Origination. Records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools 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. Condition, including Perspective: For 29 of the 40 students sampled for testing the timeliness and accuracy of the University’s reporting of Pell disbursements to the COD, the student’s Pell disbursement was not reported within 15 calendar days of when the disbursement was made to the students. Cause and Effect: During the beginning of the fall semester, the University implemented various system patches that impacted the timely reporting of certain batched information containing student disbursement data to be submitted to COD. While the University did identify the issue timely due to the related system changes they were unable to submit student disbursement information to the COD within the required 15 days of disbursement. Questioned Costs: No questioned costs were identified. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend the University enhances its current policies and procedures to ensure the timely reporting of Pell disbursements to COD. Views of Responsible Officials: Lehigh University accepts this finding. We are aware of the 15 calendar day requirement and have always met the deadline. Failure to report Pell Grant disbursements within 15 days in August of 2022 was the result of a well documented Ellucian defect that denied Lehigh the ability to obtain the required data from our Banner system. By the time Lehigh received a patch from Ellucian, we had missed the 15 day window. Ellucian acknowledged the bug and Lehigh accepted that it was an anomaly.