Finding Text
Finding 2023-002 – Reporting – Significant Deficiency in Internal Control
Federal Program: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063 Federal Pell Grant Program
Federal Agency: Department of Education
Award Year: July 1, 2022 – June 30, 2023
Criteria: Institutions must report student disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition and Context: During our testwork over 40 students who received Pell Grant funds, we identified 2 students in which the College did not accurately and timely report the disbursement to COD.
Cause and Effect: The College’s control failed in detecting that untimely information was reported to COD.
Isolated or Systemic: Systemic.
Questioned Costs: None noted.
Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding: No.
Recommendation: We recommend that the College enhance its internal controls to ensure all Pell disbursements are reported to COD within 15 days from the initial disbursement.
View of Responsible Officials: The Office of Financial Aid concurs with the audit of Pell 15-day reporting finding. The Compliance is clearly stated the timeframe to send an original Pell Grant disbursement to COD is within 15 days of the date of disbursement. We also understand we have the ability to go back into the account and make an adjustment as needed. As of September 2023, Whittier College has reached out to our software vendor Ellucian Banner to find a solution on how to avoid these incidents of not sending Pell Grant disbursements to COD in the timeframe allotted for compliance. We have now been given a new process that will solve this issue to ensure the Pell Grants are all originated on COD thus allowing the disbursements to be sent within the 15-day compliance timeframe. We will continue to reconcile the Pell Grants twice a month internally to ensure any issues get resolved, if any noted, in a timely manner.