Finding 538994 (2024-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 349701
Organization: Holyoke Community College (MA)

AI Summary

  • Core Issue: The College failed to report a Pell Grant disbursement to COD within the required 15-day timeframe, with a delay of 7 days for 1 out of 40 students tested.
  • Impacted Requirements: Compliance with 34 CFR 690.83(b) and Federal Register guidelines for timely reporting of disbursement records.
  • Recommended Follow-Up: Management should review and update reporting policies and procedures to ensure timely submission of all Pell Grant funds.

Finding Text

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change 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 to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the 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 the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 1 student, out of a sample of 40, that was not reported within the required timeframe by 7 days. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The College did not report Pell Grant disbursements to COD within the required time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, was determined to be reported late to the COD by 7 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Corrective Action Plan: To prevent conflicts between student work schedules and class schedules, the Financial Aid Office will verify, at the beginning of each term, that Federal Work-Study (“FWS”) student work schedules do not conflict with their academic schedules. As part of this verification process, department managers hiring FWS students will submit both the student's work schedule and class schedule to the Financial Aid Office. A report has been developed to compare FWS student work hours with their class schedules during each pay period. Any instances of students working during scheduled class time will be communicated to both the student and their supervisor for correction, if the hours were reported in error. If the hours are accurate, the department must provide documentation of a class schedule change, cancellation, or the fund and organization codes to be charged, crediting the FWS funds accordingly. Timeline for Implementation of Corrective Action Plan: This policy will be implemented immediately and applied retroactively to July 1, 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Curt Foster, Comptroller

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 538991 2024-001
    Significant Deficiency Repeat
  • 538992 2024-001
    Significant Deficiency Repeat
  • 538993 2024-002
    Significant Deficiency
  • 1115433 2024-001
    Significant Deficiency Repeat
  • 1115434 2024-001
    Significant Deficiency Repeat
  • 1115435 2024-002
    Significant Deficiency
  • 1115436 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $7.32M
84.268 Federal Direct Student Loans $5.55M
84.042 Trio_student Support Services $721,443
21.027 Coronavirus State and Local Fiscal Recovery Funds $644,161
47.076 Education and Human Resources $462,084
84.031 Higher Education_institutional Aid $442,821
93.732 Mental and Behavioral Health Education and Training Grants $411,724
84.048 Career and Technical Education -- Basic Grants to States $223,881
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $185,719
84.007 Federal Supplemental Educational Opportunity Grants $165,747
84.033 Federal Work-Study Program $145,066
84.425 Education Stabilization Fund $105,119
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $77,360
84.002 Adult Education - Basic Grants to States $23,460