Finding Text
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner.
Condition – The University did not ensure accurate origination and disbursement reporting to the COD.
Questioned Costs – None noted.
Context – Out of a population of 2,221 students receiving Direct Loan and/or Pell awards during the year, a sample of 40 students were selected for testing. Five errors were noted. There were three instances in which the student's disbursement date was not consistent with the COD, and two instances in which the student's pell award amount was not consistent with the COD. The sample was not, and was not intended to be, a statistically valid sample.
Effect – The University did not report the accurate data (e.g., disbursement dates and amounts) to the COD.
Cause – Lack of reconciliation of student origination records to data provided to the COD.
Identification as a Repeat Finding – Yes, see prior year finding 2022-003
Recommendation – The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD.
Views of Responsible Officials and Planned Corrective Actions – Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of the next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.