Finding 381009 (2023-001)

Finding No.: 2023-001 –Reporting Federal Agency: Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Number: 84.268, 84.063 Federal Award Numbers: P268K230183, P063P220183 Federal Award Year: July 1, 2022 – June 30, 2023 Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. Key items to test on disbursement records are disbursement date and amount. Institutions must report all loan disbursements and submit required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had differences in disbursement dates per the institution’s records than what was reported within the COD system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within required timeframe. The University did not have an internal control process in place to ensure required information reported to COD was accurate to the institutions’ records. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials The University must improve our quality controls to ensure these dates match in the future and take steps to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program review, a corrective action plan has already been implemented. That plan includes the following action steps: 1. Boston University has changed the COD disbursement schedule to only occur during defined business hours and only on defined days of the week (Monday and Wednesday). This change to the disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the federal financial aid credits to the individual student account. 2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the student’s BU student account. 3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date inconsistencies with student account credits and make updates to COD when inconsistencies occur