Finding Text
Criteria
According to 34 CFR 690.83(b):
(1) An institution shall report to the Secretary any change for which a student qualifies including any
related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses
the basis and result of the change in award for each student. The institution shall submit the student’s
Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the
Federal Register.
(2) An institution shall submit, in accordance with the deadline dates established by the Secretary,
through publication in the Federal Register, other reports and information the Secretary requires and shall
comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
According to the Federal Register (Volume 86, Number 119):
An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant
disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of
the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV,
Higher Education Act (“HEA”) program funds are disbursed on the date that the institution:
(a) Credits those funds to a student’s account in the institution’s general ledger or any subledger
of the general ledger; or
(b) pays those funds to a student directly.
Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of
receiving program funds from the Department of Education.
Condition
Federal regulations require the College to report to the Federal Government’s Common Origination and
Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds
being disbursed to the student. During our testing, we noted four students out of a sample of forty were not
reported within the required timeframe by 96-280 days.
Cause
The College has policies and procedures in place to report the disbursement records to the Department of
Education through the COD system within the required fifteen calendar days; however, in this case the
procedures were not completed properly. Late reporting was due to significant personnel turnover in the financial
aid department of the College causing delay in the correction of rejected COD reporting.
Effect
The College did not report Pell Grant disbursements to COD within the required time frame.Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the forty students selected for testing, four
students, or 10% of our sample, was determined to be reported late to the COD.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
We recommend that management of the College train additional financial aid department staff on the COD
reporting procedures to ensure Pell Grant funds are reported within the required timeframe when management or
other staffing has been disrupted.
View of Responsible Officials
The College agrees with the finding. The Student Financial Services department experienced significant
employee turnover in fiscal year 2023. This resulted in a disruption to the process of following up and responding
to rejected COD reporting within the required 15-day timeframe.