Finding 546951 (2024-002)

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 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 38 Pell Grant recipients, was not reported within the required timeframe by 17 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 error identified above relates to Pell Grant disbursement reporting; however, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculations as student interest accrues based on the disbursement date reported to COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 38 students selected for testing, 1 student, or 2.6% of our sample, was determined to be reported late to the COD. Identification as a Repeat Finding, if applicable Identified as a repeat of finding 2023-002 in the prior year single audit report. 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.