Finding Text
Federal Program Information: Federal Pell Grant Program (ALN 84.063)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (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. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “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.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD.
Views of Responsible Officials: The student that was not reported within 15 calendar days as required had several outliers making it difficult to determine Pell amounts. The student had attended another university Summer 2022 and this particular university awarded the student’s Pell Grant off of the 22-23 award year. While this is an accepted practice, it can affect the student’s 22-23 Pell Grant eligibility if they transfer to another institution. This student did transfer to Methodist University (MU) Fall 2022 and attended Fall 2022, Spring 2023, and Summer 2023. The student still had Pell eligibility remaining to be awarded Pell Grant at MU for Summer 23, but there was a rounding issue (PowerFAIDS rounds up) and this caused a POP (Potential Pell Overpayment) situation with MU and the prior university. The adjustment was processed outside of the required timeframe with COD; however, the award amounts were appropriately addressed and corrected. This is a unique situation and happens rarely. The Office of Financial Aid will review more carefully when awarding Pell Grant for rounding issues.