Finding Text
2023-002 Special Tests and Provisions
Federal agency: U.S Department of Education
Federal program title: Student Financial Assistance Cluster
Assistant Listing Number: 84.007/84.033/84.063/84.268
Federal Award Identification Number: P007A221105 - P033A221105 - P063P221336 - P268K231336
Award Period: July 1, 2022 to June 30, 2023
Type of Finding:
• Compliance, Other Matters
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College did not timely report all disbursement dates and amounts to the COD system.
Context: We identified 2 out of 40 COD disbursements tested that were not reported within the required 15 days to COD, these two instances were reported 7 days late.
Questioned costs: None.
Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat Finding: No.
Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date.
Views of responsible officials: Management agrees with the finding.