Finding Text
2023-003 Reporting
U.S. Department of Education:
Student Financial Assistance Cluster – Federal Pell Grant Program (ALN 84.063)
Federal Award Number and Year: P063P201813 (7/1/22 – 6/30/23)
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Prior Year Finding: 2022-004
Finding Type: Material Weakness and Material Noncompliance
Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data 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. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that the Pell reporting requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program.
Condition and Context
The University has a process in place to submit the required information to COD on a weekly basis. For the 40 selections we tested, there were 8 instances of noncompliance where the University failed to report student disbursement data related to Pell Awards within 15 calendar days. Additionally, the University did not have a properly designed and operating effectively internal control in place to review the ED acknowledgement reports or to ensure disbursement data was reported within the 15-calendar day requirement.
Cause
The University did not have a process in place to maintain the documentation regarding the existence or performance of the control.
Effect
The University is not in compliance with the Federal requirements to report disbursement data and maintain documentation of its internal controls over the 15-calendar day reporting compliance requirement.
Questioned Costs
There are no known questioned costs related to this finding.
Recommendation
We recommend that the University strengthen its policies, procedures and controls over Pell reporting in relation to the Student Financial Assistance Cluster. We also recommend that the University ensure that internal controls in place surrounding the 15-calendar day reporting process are performed as designed and documentation is maintained.
Views of Responsible Official
The University agrees with the finding. The University has had a significant amount of staff turnover and reorganization in fiscal year 2023 in the financial aid office. The Interim Director of Financial Aid is collaborating with the Controller’s office to make sure that the University has internal controls in place over Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal statutes, regulation and terms and conditions of the federal award. The University is investing in making sure that the Financial Aid Office is staffed and creates policies and procedures that assure that we improve internal controls over the Pell reporting process.