Finding Text
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268, 84.063, Federal Direct Student Loans - Award Year 2022 Federal Pell Grant Program - 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 University's billing system did not agree with the reportd dates per the Common Origination Disbursement (COD) records. Cost of attendance transaction numbers, and the Pell award amount did not agree between the students' file and COD records. Questioned Costs ? None noted. Context ? Out of a population of 931 students receiving Direct Loan awards and 541 students receiving Pell awards during the year, a sample of 40 students were selected for testing. Thirteen errors were noted. There were five instances in which the student's COA were not consistent with the COD for Pell awards. There were five instances in which the student's disbursement date was not consistent with the COD, and three instances in which the student's transaction code was not consistent with the COD for Direct Loan awards. The sample was not, and was not intended to be, a statistically valid sample. Effect ? The University 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 ? No Recommendation ? The University 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 - Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.