Finding Text
Finding number: 2022-004
Federal agency: U.S. Department of Education
Programs: Student Financial Assistance Cluster
Assistance Listing #: 84.063 and 84.268
Award year: 2022
Compliance Requirement: Cash Management and Reporting
Criteria
According to 34 CFR 690.83(b)
(1) An institution shall report to the Secretary any change in the amount of a grant 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 change to the
Secretary by the reporting deadlines published by the Secretary in the Federal Register.
(2) An institution shall submit, in accordance with 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 Common Origination and Disbursement (“COD”) 2021-2022 Technical Reference:
Disbursement Date is the date the money was credited to the student’s account or paid to the
student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement
Date is not the date of the adjustment transaction. The Disbursement Date is
submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount
transaction.
Condition
Federal regulations require the College to report the Federal Government’s COD Federal Pell
Grant and Direct Loan disbursements made to students. During our testing, we noted for 1 student,
out of a sample of 40, that the amount of the funds credited to the student's account did not match
with the COD disbursed amount. Additionally, for 3 students, out of a sample of 40, the disbursed
date in the student account did not align with the disbursed date in the COD by a range of 1-5 days.
Our sample was not, and was not intended to be, statistically valid.
Cause
The College did not have adequate internal controls in place to validate that the disbursement
amount and disbursement date per the student's account statement matched the disbursement
amount and disbursement date reported to COD.
Effect
The College did not report the correct disbursement amount and date to the COD.
Questioned Costs
Not applicable
Identification as a Repeat Finding, if applicable
See finding 2021-003 included in the summary schedule of prior year findings.
Recommendation
The College should implement internal control procedures to ensure that COD disbursement
information matches the College's records.
View of Responsible Officials
The College agrees with the finding.