Finding No.: 2023-001 –Reporting
Federal Agency: Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Number: 84.268, 84.063
Federal Award Numbers: P268K230183, P063P220183
Federal Award Year: July 1, 2022 – June 30, 2023 Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or
disbursement records and returns acknowledgments to the institution. Key items to test on disbursement
records are disbursement date and amount. Institutions must report all loan disbursements and submit
required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found
Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had
differences in disbursement dates per the institution’s records than what was reported within the COD
system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect
Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within
required timeframe. The University did not have an internal control process in place to ensure required
information reported to COD was accurate to the institutions’ records.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials
The University must improve our quality controls to ensure these dates match in the future and take steps
to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program
review, a corrective action plan has already been implemented. That plan includes the following action
steps:
1. Boston University has changed the COD disbursement schedule to only occur during defined business
hours and only on defined days of the week (Monday and Wednesday). This change to the
disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the
federal financial aid credits to the individual student account.
2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown
mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule
jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the
student’s BU student account.
3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date
inconsistencies with student account credits and make updates to COD when inconsistencies occur
Finding No.: 2023-001 –Reporting
Federal Agency: Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Number: 84.268, 84.063
Federal Award Numbers: P268K230183, P063P220183
Federal Award Year: July 1, 2022 – June 30, 2023 Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or
disbursement records and returns acknowledgments to the institution. Key items to test on disbursement
records are disbursement date and amount. Institutions must report all loan disbursements and submit
required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found
Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had
differences in disbursement dates per the institution’s records than what was reported within the COD
system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect
Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within
required timeframe. The University did not have an internal control process in place to ensure required
information reported to COD was accurate to the institutions’ records.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials
The University must improve our quality controls to ensure these dates match in the future and take steps
to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program
review, a corrective action plan has already been implemented. That plan includes the following action
steps:
1. Boston University has changed the COD disbursement schedule to only occur during defined business
hours and only on defined days of the week (Monday and Wednesday). This change to the
disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the
federal financial aid credits to the individual student account.
2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown
mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule
jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the
student’s BU student account.
3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date
inconsistencies with student account credits and make updates to COD when inconsistencies occur
Finding No.: 2023-001 –Reporting
Federal Agency: Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Number: 84.268, 84.063
Federal Award Numbers: P268K230183, P063P220183
Federal Award Year: July 1, 2022 – June 30, 2023 Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or
disbursement records and returns acknowledgments to the institution. Key items to test on disbursement
records are disbursement date and amount. Institutions must report all loan disbursements and submit
required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found
Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had
differences in disbursement dates per the institution’s records than what was reported within the COD
system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect
Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within
required timeframe. The University did not have an internal control process in place to ensure required
information reported to COD was accurate to the institutions’ records.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials
The University must improve our quality controls to ensure these dates match in the future and take steps
to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program
review, a corrective action plan has already been implemented. That plan includes the following action
steps:
1. Boston University has changed the COD disbursement schedule to only occur during defined business
hours and only on defined days of the week (Monday and Wednesday). This change to the
disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the
federal financial aid credits to the individual student account.
2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown
mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule
jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the
student’s BU student account.
3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date
inconsistencies with student account credits and make updates to COD when inconsistencies occur
Finding No.: 2023-001 –Reporting
Federal Agency: Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Number: 84.268, 84.063
Federal Award Numbers: P268K230183, P063P220183
Federal Award Year: July 1, 2022 – June 30, 2023 Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or
disbursement records and returns acknowledgments to the institution. Key items to test on disbursement
records are disbursement date and amount. Institutions must report all loan disbursements and submit
required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found
Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had
differences in disbursement dates per the institution’s records than what was reported within the COD
system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect
Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within
required timeframe. The University did not have an internal control process in place to ensure required
information reported to COD was accurate to the institutions’ records.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials
The University must improve our quality controls to ensure these dates match in the future and take steps
to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program
review, a corrective action plan has already been implemented. That plan includes the following action
steps:
1. Boston University has changed the COD disbursement schedule to only occur during defined business
hours and only on defined days of the week (Monday and Wednesday). This change to the
disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the
federal financial aid credits to the individual student account.
2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown
mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule
jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the
student’s BU student account.
3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date
inconsistencies with student account credits and make updates to COD when inconsistencies occur
Finding No.: 2023-001 –Reporting
Federal Agency: Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Number: 84.268, 84.063
Federal Award Numbers: P268K230183, P063P220183
Federal Award Year: July 1, 2022 – June 30, 2023 Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or
disbursement records and returns acknowledgments to the institution. Key items to test on disbursement
records are disbursement date and amount. Institutions must report all loan disbursements and submit
required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found
Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had
differences in disbursement dates per the institution’s records than what was reported within the COD
system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect
Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within
required timeframe. The University did not have an internal control process in place to ensure required
information reported to COD was accurate to the institutions’ records.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials
The University must improve our quality controls to ensure these dates match in the future and take steps
to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program
review, a corrective action plan has already been implemented. That plan includes the following action
steps:
1. Boston University has changed the COD disbursement schedule to only occur during defined business
hours and only on defined days of the week (Monday and Wednesday). This change to the
disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the
federal financial aid credits to the individual student account.
2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown
mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule
jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the
student’s BU student account.
3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date
inconsistencies with student account credits and make updates to COD when inconsistencies occur
Finding No.: 2023-001 –Reporting
Federal Agency: Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Number: 84.268, 84.063
Federal Award Numbers: P268K230183, P063P220183
Federal Award Year: July 1, 2022 – June 30, 2023 Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or
disbursement records and returns acknowledgments to the institution. Key items to test on disbursement
records are disbursement date and amount. Institutions must report all loan disbursements and submit
required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found
Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had
differences in disbursement dates per the institution’s records than what was reported within the COD
system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect
Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within
required timeframe. The University did not have an internal control process in place to ensure required
information reported to COD was accurate to the institutions’ records.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials
The University must improve our quality controls to ensure these dates match in the future and take steps
to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program
review, a corrective action plan has already been implemented. That plan includes the following action
steps:
1. Boston University has changed the COD disbursement schedule to only occur during defined business
hours and only on defined days of the week (Monday and Wednesday). This change to the
disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the
federal financial aid credits to the individual student account.
2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown
mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule
jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the
student’s BU student account.
3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date
inconsistencies with student account credits and make updates to COD when inconsistencies occur
Finding No.: 2023-001 –Reporting
Federal Agency: Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Number: 84.268, 84.063
Federal Award Numbers: P268K230183, P063P220183
Federal Award Year: July 1, 2022 – June 30, 2023 Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or
disbursement records and returns acknowledgments to the institution. Key items to test on disbursement
records are disbursement date and amount. Institutions must report all loan disbursements and submit
required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found
Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had
differences in disbursement dates per the institution’s records than what was reported within the COD
system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect
Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within
required timeframe. The University did not have an internal control process in place to ensure required
information reported to COD was accurate to the institutions’ records.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials
The University must improve our quality controls to ensure these dates match in the future and take steps
to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program
review, a corrective action plan has already been implemented. That plan includes the following action
steps:
1. Boston University has changed the COD disbursement schedule to only occur during defined business
hours and only on defined days of the week (Monday and Wednesday). This change to the
disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the
federal financial aid credits to the individual student account.
2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown
mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule
jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the
student’s BU student account.
3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date
inconsistencies with student account credits and make updates to COD when inconsistencies occur
Finding No.: 2023-001 –Reporting
Federal Agency: Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Number: 84.268, 84.063
Federal Award Numbers: P268K230183, P063P220183
Federal Award Year: July 1, 2022 – June 30, 2023 Criteria
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement
records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or
disbursement records and returns acknowledgments to the institution. Key items to test on disbursement
records are disbursement date and amount. Institutions must report all loan disbursements and submit
required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found
Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had
differences in disbursement dates per the institution’s records than what was reported within the COD
system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect
Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within
required timeframe. The University did not have an internal control process in place to ensure required
information reported to COD was accurate to the institutions’ records.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials
The University must improve our quality controls to ensure these dates match in the future and take steps
to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program
review, a corrective action plan has already been implemented. That plan includes the following action
steps:
1. Boston University has changed the COD disbursement schedule to only occur during defined business
hours and only on defined days of the week (Monday and Wednesday). This change to the
disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the
federal financial aid credits to the individual student account.
2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown
mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule
jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the
student’s BU student account.
3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date
inconsistencies with student account credits and make updates to COD when inconsistencies occur