Finding 539047 (2024-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 349756
Organization: Santa Clara University (CA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The University failed to report 5 out of 40 student disbursements to the COD system within the required 15-day timeframe.
  • Impacted Requirements: Compliance with federal regulations requiring timely reporting of student disbursement data.
  • Recommended Follow-Up: Improve internal controls to ensure all disbursements are reported to COD within the 15-day deadline.

Finding Text

Finding 2024-001 Federal Program: Student Financial Assistance Cluster Listing Number: 84.268 Federal Direct Student Loans Program 84.063 Federal Pell Grant Program Federal Agency: Department of Education Award Year: July 1, 2023 – June 30, 2024 Criteria: In accordance with 86 Federal Registrar 33245, institutions must report student disbursement data to Common Origination and Disbursement (COD) system 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 disbursements are reported in a timely manner. Condition and Context: Of the 40 Pell Grant or Direct Loan disbursements we selected for test work, we identified 5 students in which the University did not timely report the disbursement to COD. Possible Cause and Effect: The University’s internal control process failed to ensure the timely reporting of disbursements to COD. Isolated or Systemic: Systemic. Questioned Costs: None noted. Whether the sampling was The sample was not intended to be, and was not, a statistically valid a statistically valid sample: sample. Repeat Finding: No. Recommendation: We recommend that the University enhance its internal controls to ensure all Pell and Direct Loan disbursements are reported to COD within 15 days from the initial disbursement.

Corrective Action Plan

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-001: Criteria Institutions must report disbursement data to Common Origination and Disbursement (COD) system 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 disbursements are reported in a timely manner. Statement of Condition During testwork, KPMG selected 40 students that had Pell Grant or Direct Loan disbursements where the University was required to report student disbursement date to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes award of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. KPMG identified 5 of the 40 students were not reported to COD in a timely manner. Corrective Action Planned The University agrees with this assessment and is implementing a new process to ensure Direct Loan and Pell Grant disbursements will now be reviewed after each disbursement (Monday, Wednesday, and Friday) and are reported within the Department of Education's requirements. Additionally, we will ensure that the COD Workday outbound and inbound integrations are monitored daily. Name of contact Person responsible for corrective action plan Sandra Hayes, Assistant Vice President for Enrollment Management Anticipated completion date The above measures have already been implemented.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 539048 2024-001
    Significant Deficiency
  • 539049 2024-002
    Significant Deficiency
  • 539050 2024-002
    Significant Deficiency
  • 1115489 2024-001
    Significant Deficiency
  • 1115490 2024-001
    Significant Deficiency
  • 1115491 2024-002
    Significant Deficiency
  • 1115492 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $58.33M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4.66M
84.063 Federal Pell Grant Program $4.10M
84.038 Federal Perkins Loan Program $1.70M
84.007 Federal Supplemental Educational Opportunity Grants $697,000
84.033 Federal Work-Study Program $642,791
43.000 NASA Wyle Laboratories $510,568
47.041 Engineering $488,867
93.859 Biomedical Research and Research Training $451,204
47.076 Education and Human Resources $352,255
16.746 Capital Case Litigation Initiative $274,042
93.242 Mental Health Research Grants $265,167
12.300 Basic and Applied Scientific Research $226,689
84.365Z English Language Acquisition, Enhancement, and Academic Achievement $180,859
16.820 Postconviction Testing of Dna Evidence $147,493
11.609 Measurement and Engineering Research and Standards $92,026
16.U04 Victims of Human Trafficking $76,374
81.RD Physical Sciences Incorporated $59,934
15.648 Central Valley Project Improvement Act (cvpia) $46,651
47.083 Integrative Activities $41,880
93.242 University of Southern Florida $36,313
16.U05 Victims of Human Trafficking $34,402
47.079 Office of International Science and Engineering $30,713
12.900 Language Grant Program $26,920
47.075 Social, Behavioral, and Economic Sciences $26,768
47.070 Computer and Information Science and Engineering $19,344
47.074 Biological Sciences $16,970
93.242 Columbia University $16,666
47.049 Mathematical and Physical Sciences $15,615
81.RD Stanford University $13,065
47.071 Engineering Grants $10,400
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $8,502