Finding Text
FINDING 2022-001 ? CONTROLS AND NONCOMPLIANCE OVER REPORTING Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education?s Common Origination and Disbursement (COD) site within 15 days. Condition During our testing of controls over reporting it is noted that the College did not maintain proper documentation in the form of a list of files that are reviewed by the Student Financial Aid Director for accuracy before being submitted to the COD. Additionally, during our compliance testing we noted 8 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 30 day submission window. Questioned Costs None Context The College was unable to locate its control documentation that COD site submissions were reviewed for accuracry and approved prior to submission. A sample of 25 students were selected for compliance testing. 8 students? disbursement information was submitted between 3 and 17 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2021-003. Recommendation We recommend that the College?s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College?s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.