Finding Text
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.