Finding 371031 (2023-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-02-28
Audit: 292694
Organization: William Jessup University (CA)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: Discrepancies between actual disbursement dates and reported dates for Federal Direct Loans and Pell Grants.
  • Impacted Requirements: Compliance with 34CFR 668.164(a) regarding accurate reporting of disbursement dates.
  • Recommended Follow-Up: Implement procedures to ensure COD reporting aligns with actual disbursement dates.

Finding Text

Common Origination and Disbursement (COD) Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The dates when Federal Direct Loans (FDL) and Pell were disbursed to student's account did not always agree to the disbursement dates as reported in COD. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Out of 259 subsidized, unsubsidized, Plus loans, and Pell disbursement records tested, 25 had COD loan and Pell disbursement date errors. The errors were primarily a spring 2023 disbursement batch which reported Pell and FDL disbursements to COD as 2/21/2023 but were actually posted to the students’ accounts on 3/24/2023. There were no errors in the amounts reported, just the date of disbursement and the funds were not drawn down from G5 until 3/28/2023 so no cash management violation noted. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students' accounts. Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not realized that the date must match exactly. We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of our disbursing of Title IV funds. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024

Categories

Student Financial Aid Cash Management Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $8.39M
84.063 Federal Pell Grant Program $1.97M
84.033 Federal Work-Study Program $157,136
84.007 Federal Supplemental Educational Opportunity Grants $96,780
20.111 Aircraft Pilots Workforce Development Grant Program $75,133
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $37,588
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $20,109