Finding Text
FINDING #2023-001 – INTERNAL CONTROLS OVER FEDERAL AWARDS
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance
Criteria or Specific Requirement: In accordance with 2 CFR 200.303, nonfederal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition / Context: During our audit procedures, we noted instances where a student was overpaid student financial aid due to changes in student units. The amounts reported to the Common Origination and Disbursement system were correctly reported resulting in the overpayment being disbursed from the District’s funds.
Questioned Costs: None.
Cause: Inadequate controls over student information changes allowing the institution to identify changes in enrollment and adjust financial aid accordingly.
Effect: Overpayment by the District where the District must use funds from the General Fund to cover the overpayment.
Repeat Finding: No.
Recommendation: We recommend the institution review its processes over student information changes and ensure that students are being awarded the proper amount of financial aid based on enrollment at the time of disbursement to prevent having to cover overpayments through the General Fund.
Corrective Action Plan: These initial Pell overpayments were incurred in the “early” Pell disbursements that occurred a week before the semester started and the first two weeks of the semester. The enrollment was reported correctly, but part of the issue was the current FA system (SAM) was not programmed to adjust the amount disbursed based on the student’s current enrollment at the time of disbursement. For the Spring 2024 semester, testing will be done on SAM to disburse aid based on current enrollment for the early disbursements. If successful, this change will reduce the amount in overpayments if students drop below ½ time for the semester, or withdraw completely.
In addition, the Financial Aid Office is transitioning from the SAM to the Colleague Financial Aid System (starting in 2024-25). Colleague is already programmed to disburse aid based on current enrollment status, so this will not be a recurring issue in the future.
Early Disbursement and Overpayment Notes:
• The 1st early Pell disbursement is based on 25% of a student’s semester award based on full-time enrollment. If a student is currently enrolled ½-time or higher when this disbursement is processed, they will receive the 25% award amount. If a student is enrolled in less than ½-time status (.5 units to 5.5 units), they will receive a $500 Pell disbursement to account for the lower semester Pell grant award for less than ½-time students.
• We understand students add/drop courses through the first two weeks of the semester. The final Pell grant award for the semester is adjusted to the student’s enrollment status on Census day. Students who are ½-time or higher at Census will not be a Pell overpayment for the semester since their Pell grant award will be at 50% or higher.
• For students who were enrolled at ½-time or higher at the time the early disbursement was processed, but then dropped to less than ½-time or withdrew completely by Census day, they will be considered a Pell overpayment.
o These types of overpayments are unavoidable. However, we will work on minimizing the dollar amount of these types of overpayments with the actions stated above. We will test the current FA system (SAM) to disburse the early disbursements based on current enrollment status before Census and monitor closely.
o Example: Currently, if a student is scheduled a $500 disbursement for the early 25% disbursement, and is enrolled ½ time, they will receive $500. With the change to actual enrollment (1/2 time for this case), the student will receive $250 instead of $500. If the student drops below ½-time or withdraws completely by census, the highest overpayment amount will be $250 instead of $500.