Finding 388092 (2023-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299928
Organization: Greenfield Community College (MA)

AI Summary

  • Core Issue: The College failed to report a Pell Grant disbursement to the COD within the required 15-day timeframe, missing it by 11 days.
  • Impacted Requirements: Compliance with 34 CFR 690.83(b) and Federal Register guidelines for timely reporting of financial aid disbursements.
  • Recommended Follow-up: Management should review and update reporting policies and procedures to ensure compliance with deadlines for all Pell Grant disbursements.

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 83, Number 233): 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. 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 1 student, out of a sample of 40, that was not reported within the required timeframe by 11 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. 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 40 students selected for testing, 1 student, or 2.5% of our sample, was determined to be reported late to the COD by 11 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Finding number: 2023-002 Corrective Action Plan: To ensure that the college is using the same effective date for (unofficial) withdrawal on both the R2T4 calculations and for reporting unofficial withdrawal enrollment changes to NSLDS, the financial aid office will forward the list of students who are determined to have unofficially withdrawn and their associated date of unofficial withdrawal to the registrar's office at the end of each term. The registrar's office will then adjust all students' records in their SIS (Banner) as needed prior to submitting their report to NSC/NSLDS. The registrar's office will have an established workflow in place to process these changes prior to the end of the spring 2024 term. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Mark Boudreau, Comptroller

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 388090 2023-001
    Significant Deficiency
  • 388091 2023-001
    Significant Deficiency
  • 964532 2023-001
    Significant Deficiency
  • 964533 2023-001
    Significant Deficiency
  • 964534 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.57M
84.268 Federal Direct Student Loans $609,071
84.048 Career and Technical Education -- Basic Grants to States $241,470
84.033 Federal Work-Study Program $148,411
10.225 Community Food Projects $88,475
84.007 Federal Supplemental Educational Opportunity Grants $59,918
84.425 Education Stabilization Fund $46,154
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $39,773
84.031 Higher Education_institutional Aid $39,152
17.282 Trade Adjustment Assistance Community College and Career Training (taaccct) Grants $38,517
97.067 Homeland Security Grant Program $9,792