Finding Text
Student Financial Assistance Cluster U.S. Department of Education Federal Direct Student Loans 84.268 Federal Pell Grant Program 84.063 Award Year 2022 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 and Pell disbursement dates per the College's billing system did not agree with the reported dates per the Common Origination Disbursement (COD) records. Cost of attendance, transaction numbers, and the Pell award amount did not agree between the student?s files and COD records. Questioned Costs - None. Context - Out of a population of 159 students receiving Direct Loan awards during the year, a sample of 24 students was selected for testing. Out of these 24 students selected for testing, there were three instances in which the student's transaction code per the College's origination records was not consistent with the COD. The sample was not, and was not intended to be, a statistically valid sample. Out of a population of 251 students receiving Pell awards during the year, a sample of 25 students was selected for testing. Out of these 25 students selected for testing, there were nine instances in which the student's Cost of Attendance were not consistent with the COD. There were four instances in which the student's disbursement date per the College's records was not consistent with the COD. Finally, there was one instance in which the student's disbursement amount per the College's records was not consistent with the COD. The sample was not, and was not intended to be, a statistically valid sample. Effect - The College did not report the accurate data (e.g., disbursement dates, amounts, and cost of attendance) to the COD. Cause - Lack of reconciliation of student origination records to data provided to the COD. Identification as a Repeat Finding - Yes, see 2021-002, 2020-004 and 2019-003. Recommendation - The College should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD. Views of Responsible Officials and Planned Corrective Actions - This was neglected due to staffing issues and high turnover. Pell and Direct Loan origination records and disbursement records are submitted to the Common Origination Disbursement (COD) either same business day, or next business day. Formal reconciliation process is now completed every 1-2 months in order to verify disbursement dates, amounts, and cost of attendance in COD.