Finding 946872 (2023-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-02-24
Audit: 292012
Organization: Bloomfield College (NJ)

AI Summary

  • Core Issue: One student’s disbursement record was submitted to COD more than 15 days late.
  • Impacted Requirements: Compliance with federal regulations requiring timely submission of Pell Grant and Direct Loan records.
  • Recommended Follow-Up: Strengthen policies to ensure timely submissions and implement a secondary review process for verification.

Finding Text

Reporting - Direct Loan and Pell Common Origination and Disbursement (“COD”) Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Student Loans (Federal Assistance Listing #84.268) Federal Award Number: P268K231804 Federal Pell Grant Program (Federal Assistance Listing #84.063) Federal Award Number: P063P221804 Federal Award Year: 2022-2023 Criteria and Context: Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (“COD”) system 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 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 program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department of Education. Condition and Sample Method: From a non-statistical sample of forty (40) students selected for COD reporting testing, we identified one (1) student whose Direct Loans or Pell disbursement record was submitted to the COD more than 15 days after the award was disbursed to the student. Cause and Effect: While the College had certain procedures in place to monitor the submission of the disbursement records, such procedures were not consistently performed on a timely basis, and therefore were not adequate to ensure that each record was submitted within the required timeframe, causing the late submission of certain disbursement records. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: We recommend that the College strengthen its policies and procedures to ensure that student disbursement records are submitted accurately to the COD within 15 days of disbursements being made to students’ accounts, and that the College maintain clear evidence that a secondary review is performed to verify that the submission was made timely.

Categories

Student Financial Aid Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 370428 2023-001
    Significant Deficiency Repeat
  • 370429 2023-001
    Significant Deficiency Repeat
  • 370430 2023-002
    Significant Deficiency
  • 370431 2023-002
    Significant Deficiency
  • 946870 2023-001
    Significant Deficiency Repeat
  • 946871 2023-001
    Significant Deficiency Repeat
  • 946873 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $6.91M
84.063 Federal Pell Grant Program $4.43M
84.042 Trio_student Support Services $293,898
84.031 Higher Education_institutional Aid $278,075
84.007 Federal Supplemental Educational Opportunity Grants $269,847
84.217 Trio_mcnair Post-Baccalaureate Achievement $258,577
84.425 Education Stabilization Fund $146,098
84.033 Federal Work-Study Program $141,734
47.076 Education and Human Resources $57,772
84.382 Strengthening Minority-Serving Institutions $54,226
93.279 Drug Abuse and Addiction Research Programs $42,948