Finding Text
Student Financial Assistance Cluster
Federal Pell Grant Program, Assistance Listing No. 84.063;
Federal Direct Student Loans, Assistance Listing No. 84.268
U.S. Department of Education
Program Year 2022-2023
Criteria or specific requirement – Reporting – According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019 an institution must submit Pell and Direct Loan origination
records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner.
Condition – Federal Direct Loan disbursement dates per the University’s billing system did not agree with the reported dates per COD records.
Questioned costs – None
Context – Out of a sample of 25 students receiving $1,187,415 of federal aid from a population of 1,938 students who received $78,006,917 in federal aid there were 21 instances in which the student’s disbursement date per the University’s records was not consistent with COD. The dates reported in COD were between 1 and 3 days after the disbursement date per the University’s records. Our sampling method was not, and was not intended to be, statistically valid.
Effect – The University did not report accurate data to COD.
Cause – Lack of detailed reconciliation of student origination records to data provided to COD.
Identification as a Repeat Finding – N/A
Recommendation – The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to COD.
Views of Responsible Officials and Planned Corrective Actions – Parker University agrees with this finding and will implement the following corrective actions.
Corrective Action Plan
While most of the reporting discrepancies occurred during the Christmas and New Year holidays ensuring that students would receive their funding in a timely manner,
Parker has put in place additional controls to ensure compliance is dependent on initial and monthly reviews.
The Academic Business Analyst and Senior Director of Financial Aid will review PowerFAIDS and ensure that disbursement dates are appropriate and accurate, 10 days prior to the start of a term, regardless of the calendar day.
Parker University will ensure that Title IV funds disbursed via PowerFAIDS are applied to student accounts via Jenzabar and reported to COD the same day.
Parker University will further enhance the monthly reconciliation process. Once SAS reports are received, imported into PowerFAIDS, and the reconciliation report is generated for the respective Title IV programs, the file will be reviewed for any discrepancies in dates between the reported To_COD_Disb_Date, From_SAS_Disb_Date, and To_Bus_Disb_Date. The Senior Accounting Analyst will identify students with discrepant dates and provide to the Compliance Officer for further review. If the Compliance Officer confirms a discrepancy, the Academic Business Analyst or Senior Director of Financial Aid will complete a second review and update the appropriate system (PowerFAIDS, Jenzabar, or COD).
Parker University will complete this data review for September disbursements by December 15, 2023 and October disbursements by December 31, 2023. It will be a part of our updated reconciliation process for subsequent months.