Finding 540997 (2024-001)

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Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 350606
Organization: New York Law School (NY)
Auditor: Cbiz CPAS PC

AI Summary

  • Core Issue: One out of 40 disbursements was reported late to the COD system, missing the 15-day requirement.
  • Impacted Requirements: Institutions must report disbursement data within 15 calendar days after making a disbursement or adjusting previously reported data.
  • Recommended Follow-Up: Implement a policy to ensure all disbursements are submitted within the required 15-day timeframe.

Finding Text

Criteria or Specific Requirement Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records to the COD ("Common Origination and Disbursement") system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes the disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected disbursement date. Condition Of the 40 disbursements selected for COD reporting testing, one disbursement was reported late compared to the required 15-day threshold. Cause At that time, the School was transitioning to a new system platform. As such, disbursement was not reported within the 15-day required timeframe. Effect As the change in status was not reported within the specified time or not reported at all, COD data was not up to date. Questioned Costs None noted. Context The auditor selected 40 students to test COD reporting and examined if the School reported the disbursement within 15 days. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend the School implement a policy where the disbursements are submitted within the 15 days.

Corrective Action Plan

We concur with the audit finding regarding the need to ensure disbursement reporting is completed within the required 15-day threshold. As stated, of the 40 disbursements selected for testing, one disbursement was reported late. The instance noted was an isolated case that occurred during the institution's transition to a new system platform. We recognize the importance of timely reporting to maintain compliance with federal regulations. Corrective Action: The Office of Student Financial Services has reinforced existing procedures to ensure that all disbursement data—specifically the disbursement date and amount—is accurately reviewed, recorded, and reported within 15 calendar days of the disbursement being made. This process is effective immediately. Additional Monitoring Measures: 1. A designated financial aid team member will conduct weekly reviews of all disbursement records to verify timely reporting. 2. A monthly reconciliation report will be generated to confirm that all disbursements made during the month have been reported within the required timeframe. 3. The Executive Director of Financial Aid will review the monthly reconciliation reports and certify compliance. 4. Calendar alerts have been implemented to prompt staff of upcoming reporting deadlines. Training and Accountability: 1. Staff responsible for disbursement reporting have been trained on the new system process for this federal requirement, which includes ongoing discussion with the Ellucian team as we continue to navigate Banner SaaS. 2. Ongoing monitoring and periodic internal audits will be conducted to ensure sustained compliance. The corrective action plan has been fully implemented and is currently in effect. We are committed to maintaining compliance with all federal regulations governing financial aid disbursements.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $30.82M
84.033 Federal Work-Study Program $864,124
84.425 Education Stabilization Fund $310,441