Finding Text
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Common Origination and Disbursement (COD) System (OMB No. 1845-0039) - All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Schools submit Pell origination records and disbursement records to the COD System. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools 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 Found, Including Perspective We identified 12 students in a sample of 40 that had Pell disbursements that were reported to the COD System after the required 15 day deadline (on average 26 days). Cause and Possible Asserted Effect Management?s control over reporting Pell disbursement data to the COD System timely did not operate effectively. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample.Repeat finding The audit finding is not a repeat of a finding in the immediately prior fiscal year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting of Pell disbursement data to the COD System within the required timeframe. Views of Responsible Officials Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-0039). The COVID-19 Pandemic has presented the financial aid office with unprecedented administrative challenges, and we continue our efforts to return to pre-pandemic norms. Management would like to acknowledge the deficiency did not result in ineligible payments to students nor required the college to return any Title IV funds. The financial aid office has implemented reporting safeguards, including a secondary review of all Pell disbursements reporting prior to the COD reporting deadline, and the Associate Vice President for Financial Aid is now actively involved in ensuring timely reporting disbursements by reviewing monthly internal reports.