Finding 544471 (2024-001)

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Criteria According to Common Origination and Disbursement ("COD") 2023-2024 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. 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 The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 1 student, out of a sample of 40, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Additionally, 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, was not reported within the required timeframe by 66 days. Cause The College did not have relevant procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD or to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days due timing mismatches between the College financial aid system and COD reporting. Effect The College did not report the correct disbursement dates to the COD or 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 students, or 2.5% of our sample, did not report the correct disbursement date to COD. Additionally, 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 66 days. Identification as a Repeat Finding, if applicable See finding 2023-001 included in the summary schedule of prior year findings. Recommendation The College should implement controls and procedures to validate that COD disbursement information matches the College's records and to ensure. We also recommend that management of the College review, and if necessary, update the policies and procedures, including internal controls, to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.