Finding Text
Criteria: Per 34 CFR 690.83, 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.
Per the Federal Student Aid Handbook, schools must submit Pell disbursement records to the Common Origination and Disbursement (COD) system no later than 15 days after making the disbursements or becoming aware of the need to adjust a previously reported disbursement.
Condition/context: Of the 25 students selected for Pell reporting testing, 19 students’ disbursement records were reported to the COD system greater than 15 days after the actual disbursement.
Cause: During the transition of Financial Aid Directors, an error occurred in the assignment of the Primary Destination Point Administrator that resulted in an inability to import and export from Colleague to Student Aid Internet Gateway (SAIG) for COD and National Student Loan Data System (NSLDS) reporting. During this time, the College was unable to export disbursement information in a timely manner, which caused a delay in the COD processing of disbursement records.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a thorough control system that provides for the timely reporting of disbursement records to the COD system.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.