Finding Text
Finding number: 2023-004
Federal agency: U.S. Department of Education
Programs: Student Financial Assistance Cluster
Assistance listing #: 84.063 and 84.268
Award year: 2023
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”) 2022-2023 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 6 students, out of a sample of 40, in which the disbursed date in the student account did not align with the disbursed date in the COD. 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 date per the student's account statement matched the disbursement date reported to COD.
Effect
The College did not report the correct disbursement date to the COD.
Questioned Costs
Not applicable.
Identification as a Repeat Finding, if applicable
See finding 2022-004 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.