Finding Text
Student Financial Assistance Cluster:
U.S. Department of Education:
Federal Pell Grant Program – ALN 84.063
Statistically valid sample: No and it was not intended to be.
Repeat finding: Not a repeat finding.
Compliance Requirement – Reporting
Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 86, Number 119, June 24, 2021). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data 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 changes are reported in a timely manner.
Condition and Context
We selected forty students who received a Pell Grant disbursement and the following exceptions.
• For two Pell Grant disbursements, the disbursement was not reported within 15 days to the COD system. Both disbursements were reported 19 days late.
Cause
The students involved in this finding were students who received Pell Grant and were enrolled in the Winter and Spring 2024 semesters. The University identified an issue in reporting for the Spring 2024 semester and the reconciliation of Pell Grant disbursements for students that received Pell Grant for the Winter and Spring 2024 semester was delayed. The disbursements were correctly reported to the COD system, however, outside of the 15 day reporting requirement.
Effect
Disbursements not reported in a timely manner could result in discrepancies between University disbursement records and COD system disbursement records.
Questioned Costs
There were no questioned costs related to this finding.
Recommendation
We recommend the University reinforces its policies and procedures for persons responsible for reporting Pell Grant disbursements to the COD system to ensure compliance with the requirement of submitting disbursements in a timely manner.
Views of Responsible Official
Management of the University agrees with the recommendation. The corrective action by Corry Unis, Vice President for Enrollment Management and Diana Draper, Executive Director of Financial Aid is as follows:
Initial corrective action was taken by Diana Draper, Financial Aid Director, in March 2024 when the student disbursements were reports to COD. Additional corrective actions included systematic controls, additional training, and greater internal monitoring and auditing have been put in place.