2023‐002 U.S. Department of Education
Student Financial Aid Cluster
Reporting – Common Origination and Disbursement (COD) System
Significant Deficiency in Internal Control over Compliance
Criteria:
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and
disbursement records to the COD system. Origination records can be sent well in advance of any
disbursements, as early as the institution chooses to submit them for any student the institution
reasonably believes will be eligible for a payment.
The acknowledgments identify the processing status of each record: Rejected, Accepted with
Corrections, or Accepted. In testing the origination and disbursement data, the auditor should
be most concerned with the data ED has categorized as accepted or accepted with corrections.
Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously
reported student disbursement data or expected student disbursement data. Institutions 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: The disbursement date recorded by the COD for financial aid and the disbursement to student
by the District was greater than the allowable period of 15 calendar days for one item.
Questioned
Costs: None
Effect: Untimely reporting of student enrollment status does not allow the Department of Education to
properly track and monitor students, including initiation of the loan repayment process.
Cause: The delay in actual disbursement is believed to be contributed to the District reviewing the costs
of the Aviation Program before the disbursements was made. However, the person over the
department when this disbursement was made is currently no longer employed by the District
and the reason for the delayed disbursement cannot be clarified and records do not appear to
be retained for this item. Repeat finding
From Prior Year:
No
Context: Out of the 40 sample of students tested for COD reporting, 1 student was beyond the required
15 calendar days. Non‐statistical sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
COD reporting and proper retention of files in the event of subsequent updates from the original
transfer date.
Views of Responsible Officials:
We agree with the finding.
2023‐002 U.S. Department of Education
Student Financial Aid Cluster
Reporting – Common Origination and Disbursement (COD) System
Significant Deficiency in Internal Control over Compliance
Criteria:
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and
disbursement records to the COD system. Origination records can be sent well in advance of any
disbursements, as early as the institution chooses to submit them for any student the institution
reasonably believes will be eligible for a payment.
The acknowledgments identify the processing status of each record: Rejected, Accepted with
Corrections, or Accepted. In testing the origination and disbursement data, the auditor should
be most concerned with the data ED has categorized as accepted or accepted with corrections.
Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously
reported student disbursement data or expected student disbursement data. Institutions 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: The disbursement date recorded by the COD for financial aid and the disbursement to student
by the District was greater than the allowable period of 15 calendar days for one item.
Questioned
Costs: None
Effect: Untimely reporting of student enrollment status does not allow the Department of Education to
properly track and monitor students, including initiation of the loan repayment process.
Cause: The delay in actual disbursement is believed to be contributed to the District reviewing the costs
of the Aviation Program before the disbursements was made. However, the person over the
department when this disbursement was made is currently no longer employed by the District
and the reason for the delayed disbursement cannot be clarified and records do not appear to
be retained for this item. Repeat finding
From Prior Year:
No
Context: Out of the 40 sample of students tested for COD reporting, 1 student was beyond the required
15 calendar days. Non‐statistical sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
COD reporting and proper retention of files in the event of subsequent updates from the original
transfer date.
Views of Responsible Officials:
We agree with the finding.
2023‐002 U.S. Department of Education
Student Financial Aid Cluster
Reporting – Common Origination and Disbursement (COD) System
Significant Deficiency in Internal Control over Compliance
Criteria:
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and
disbursement records to the COD system. Origination records can be sent well in advance of any
disbursements, as early as the institution chooses to submit them for any student the institution
reasonably believes will be eligible for a payment.
The acknowledgments identify the processing status of each record: Rejected, Accepted with
Corrections, or Accepted. In testing the origination and disbursement data, the auditor should
be most concerned with the data ED has categorized as accepted or accepted with corrections.
Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously
reported student disbursement data or expected student disbursement data. Institutions 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: The disbursement date recorded by the COD for financial aid and the disbursement to student
by the District was greater than the allowable period of 15 calendar days for one item.
Questioned
Costs: None
Effect: Untimely reporting of student enrollment status does not allow the Department of Education to
properly track and monitor students, including initiation of the loan repayment process.
Cause: The delay in actual disbursement is believed to be contributed to the District reviewing the costs
of the Aviation Program before the disbursements was made. However, the person over the
department when this disbursement was made is currently no longer employed by the District
and the reason for the delayed disbursement cannot be clarified and records do not appear to
be retained for this item. Repeat finding
From Prior Year:
No
Context: Out of the 40 sample of students tested for COD reporting, 1 student was beyond the required
15 calendar days. Non‐statistical sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
COD reporting and proper retention of files in the event of subsequent updates from the original
transfer date.
Views of Responsible Officials:
We agree with the finding.
2023‐003 U.S. Department of Education
Student Financial Aid Cluster (FAL # 84.268, 84.063)
Special Test: Enrollment Reporting
Material Weakness in Internal Control over Compliance
Criteria: The National Student Loan Data System (NSLDS) is the national database of information about
loans and grants awarded to students.
Institutions are required to report enrollment information under the Pell grant and the Direct
and FFEL loan programs via the NSLDS (OMB No. 1845‐0035), although FFEL loans are no longer
made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that
would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR
682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)).
The administration of the Title IV programs depends heavily on the accuracy and timeliness of
the enrollment information reported by institutions. Institutions must review, update, and
certify student enrollment statuses, program information, and effective dates that appear on
the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website which the financial aid administrator can access for the
auditor.
Institutions are also responsible for accurately reporting all Campus‐Level Record data elements
including OPEID number, enrollment effective data, enrollment status, and certification date.
Institutions are responsible for accurately reporting all Program‐Level record data including CIP
year, credential level, published program length measurement, published program length,
program begin date, program enrollment status, and program enrollment effective date. Condition: Various discrepancies were noted between the District and NSLDS for both the Campus‐Level
and Program‐Level requirements. Further some of the data provided was provided later than
the required timelines established.
Questioned
Costs: None
Effect: Untimely and inaccurate reporting of student enrollment status does not allow the Department
of Education to properly track and monitor students, including initiation of the loan repayment
process.
Cause: Internal controls do not appear to be in place to accurately and timely identify the relevant
dates for reporting to NSLDS.
Repeat finding
From Prior Year:
No
Context: Out of the 36 sample of students tested, 23 students had at least one incorrect reporting of
Campus‐Level and Program‐Level requirements and/or considered to be reported late. Nonstatistical
sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
status date changes are being reported to NSLDS.
Views of Responsible Officials:
We agree with the finding.
2023‐003 U.S. Department of Education
Student Financial Aid Cluster (FAL # 84.268, 84.063)
Special Test: Enrollment Reporting
Material Weakness in Internal Control over Compliance
Criteria: The National Student Loan Data System (NSLDS) is the national database of information about
loans and grants awarded to students.
Institutions are required to report enrollment information under the Pell grant and the Direct
and FFEL loan programs via the NSLDS (OMB No. 1845‐0035), although FFEL loans are no longer
made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that
would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR
682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)).
The administration of the Title IV programs depends heavily on the accuracy and timeliness of
the enrollment information reported by institutions. Institutions must review, update, and
certify student enrollment statuses, program information, and effective dates that appear on
the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website which the financial aid administrator can access for the
auditor.
Institutions are also responsible for accurately reporting all Campus‐Level Record data elements
including OPEID number, enrollment effective data, enrollment status, and certification date.
Institutions are responsible for accurately reporting all Program‐Level record data including CIP
year, credential level, published program length measurement, published program length,
program begin date, program enrollment status, and program enrollment effective date. Condition: Various discrepancies were noted between the District and NSLDS for both the Campus‐Level
and Program‐Level requirements. Further some of the data provided was provided later than
the required timelines established.
Questioned
Costs: None
Effect: Untimely and inaccurate reporting of student enrollment status does not allow the Department
of Education to properly track and monitor students, including initiation of the loan repayment
process.
Cause: Internal controls do not appear to be in place to accurately and timely identify the relevant
dates for reporting to NSLDS.
Repeat finding
From Prior Year:
No
Context: Out of the 36 sample of students tested, 23 students had at least one incorrect reporting of
Campus‐Level and Program‐Level requirements and/or considered to be reported late. Nonstatistical
sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
status date changes are being reported to NSLDS.
Views of Responsible Officials:
We agree with the finding.
2023‐003 U.S. Department of Education
Student Financial Aid Cluster (FAL # 84.268, 84.063)
Special Test: Enrollment Reporting
Material Weakness in Internal Control over Compliance
Criteria: The National Student Loan Data System (NSLDS) is the national database of information about
loans and grants awarded to students.
Institutions are required to report enrollment information under the Pell grant and the Direct
and FFEL loan programs via the NSLDS (OMB No. 1845‐0035), although FFEL loans are no longer
made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that
would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR
682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)).
The administration of the Title IV programs depends heavily on the accuracy and timeliness of
the enrollment information reported by institutions. Institutions must review, update, and
certify student enrollment statuses, program information, and effective dates that appear on
the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website which the financial aid administrator can access for the
auditor.
Institutions are also responsible for accurately reporting all Campus‐Level Record data elements
including OPEID number, enrollment effective data, enrollment status, and certification date.
Institutions are responsible for accurately reporting all Program‐Level record data including CIP
year, credential level, published program length measurement, published program length,
program begin date, program enrollment status, and program enrollment effective date. Condition: Various discrepancies were noted between the District and NSLDS for both the Campus‐Level
and Program‐Level requirements. Further some of the data provided was provided later than
the required timelines established.
Questioned
Costs: None
Effect: Untimely and inaccurate reporting of student enrollment status does not allow the Department
of Education to properly track and monitor students, including initiation of the loan repayment
process.
Cause: Internal controls do not appear to be in place to accurately and timely identify the relevant
dates for reporting to NSLDS.
Repeat finding
From Prior Year:
No
Context: Out of the 36 sample of students tested, 23 students had at least one incorrect reporting of
Campus‐Level and Program‐Level requirements and/or considered to be reported late. Nonstatistical
sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
status date changes are being reported to NSLDS.
Views of Responsible Officials:
We agree with the finding.
2023‐002 U.S. Department of Education
Student Financial Aid Cluster
Reporting – Common Origination and Disbursement (COD) System
Significant Deficiency in Internal Control over Compliance
Criteria:
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and
disbursement records to the COD system. Origination records can be sent well in advance of any
disbursements, as early as the institution chooses to submit them for any student the institution
reasonably believes will be eligible for a payment.
The acknowledgments identify the processing status of each record: Rejected, Accepted with
Corrections, or Accepted. In testing the origination and disbursement data, the auditor should
be most concerned with the data ED has categorized as accepted or accepted with corrections.
Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously
reported student disbursement data or expected student disbursement data. Institutions 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: The disbursement date recorded by the COD for financial aid and the disbursement to student
by the District was greater than the allowable period of 15 calendar days for one item.
Questioned
Costs: None
Effect: Untimely reporting of student enrollment status does not allow the Department of Education to
properly track and monitor students, including initiation of the loan repayment process.
Cause: The delay in actual disbursement is believed to be contributed to the District reviewing the costs
of the Aviation Program before the disbursements was made. However, the person over the
department when this disbursement was made is currently no longer employed by the District
and the reason for the delayed disbursement cannot be clarified and records do not appear to
be retained for this item. Repeat finding
From Prior Year:
No
Context: Out of the 40 sample of students tested for COD reporting, 1 student was beyond the required
15 calendar days. Non‐statistical sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
COD reporting and proper retention of files in the event of subsequent updates from the original
transfer date.
Views of Responsible Officials:
We agree with the finding.
2023‐002 U.S. Department of Education
Student Financial Aid Cluster
Reporting – Common Origination and Disbursement (COD) System
Significant Deficiency in Internal Control over Compliance
Criteria:
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and
disbursement records to the COD system. Origination records can be sent well in advance of any
disbursements, as early as the institution chooses to submit them for any student the institution
reasonably believes will be eligible for a payment.
The acknowledgments identify the processing status of each record: Rejected, Accepted with
Corrections, or Accepted. In testing the origination and disbursement data, the auditor should
be most concerned with the data ED has categorized as accepted or accepted with corrections.
Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously
reported student disbursement data or expected student disbursement data. Institutions 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: The disbursement date recorded by the COD for financial aid and the disbursement to student
by the District was greater than the allowable period of 15 calendar days for one item.
Questioned
Costs: None
Effect: Untimely reporting of student enrollment status does not allow the Department of Education to
properly track and monitor students, including initiation of the loan repayment process.
Cause: The delay in actual disbursement is believed to be contributed to the District reviewing the costs
of the Aviation Program before the disbursements was made. However, the person over the
department when this disbursement was made is currently no longer employed by the District
and the reason for the delayed disbursement cannot be clarified and records do not appear to
be retained for this item. Repeat finding
From Prior Year:
No
Context: Out of the 40 sample of students tested for COD reporting, 1 student was beyond the required
15 calendar days. Non‐statistical sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
COD reporting and proper retention of files in the event of subsequent updates from the original
transfer date.
Views of Responsible Officials:
We agree with the finding.
2023‐002 U.S. Department of Education
Student Financial Aid Cluster
Reporting – Common Origination and Disbursement (COD) System
Significant Deficiency in Internal Control over Compliance
Criteria:
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and
disbursement records to the COD system. Origination records can be sent well in advance of any
disbursements, as early as the institution chooses to submit them for any student the institution
reasonably believes will be eligible for a payment.
The acknowledgments identify the processing status of each record: Rejected, Accepted with
Corrections, or Accepted. In testing the origination and disbursement data, the auditor should
be most concerned with the data ED has categorized as accepted or accepted with corrections.
Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously
reported student disbursement data or expected student disbursement data. Institutions 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: The disbursement date recorded by the COD for financial aid and the disbursement to student
by the District was greater than the allowable period of 15 calendar days for one item.
Questioned
Costs: None
Effect: Untimely reporting of student enrollment status does not allow the Department of Education to
properly track and monitor students, including initiation of the loan repayment process.
Cause: The delay in actual disbursement is believed to be contributed to the District reviewing the costs
of the Aviation Program before the disbursements was made. However, the person over the
department when this disbursement was made is currently no longer employed by the District
and the reason for the delayed disbursement cannot be clarified and records do not appear to
be retained for this item. Repeat finding
From Prior Year:
No
Context: Out of the 40 sample of students tested for COD reporting, 1 student was beyond the required
15 calendar days. Non‐statistical sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
COD reporting and proper retention of files in the event of subsequent updates from the original
transfer date.
Views of Responsible Officials:
We agree with the finding.
2023‐003 U.S. Department of Education
Student Financial Aid Cluster (FAL # 84.268, 84.063)
Special Test: Enrollment Reporting
Material Weakness in Internal Control over Compliance
Criteria: The National Student Loan Data System (NSLDS) is the national database of information about
loans and grants awarded to students.
Institutions are required to report enrollment information under the Pell grant and the Direct
and FFEL loan programs via the NSLDS (OMB No. 1845‐0035), although FFEL loans are no longer
made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that
would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR
682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)).
The administration of the Title IV programs depends heavily on the accuracy and timeliness of
the enrollment information reported by institutions. Institutions must review, update, and
certify student enrollment statuses, program information, and effective dates that appear on
the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website which the financial aid administrator can access for the
auditor.
Institutions are also responsible for accurately reporting all Campus‐Level Record data elements
including OPEID number, enrollment effective data, enrollment status, and certification date.
Institutions are responsible for accurately reporting all Program‐Level record data including CIP
year, credential level, published program length measurement, published program length,
program begin date, program enrollment status, and program enrollment effective date. Condition: Various discrepancies were noted between the District and NSLDS for both the Campus‐Level
and Program‐Level requirements. Further some of the data provided was provided later than
the required timelines established.
Questioned
Costs: None
Effect: Untimely and inaccurate reporting of student enrollment status does not allow the Department
of Education to properly track and monitor students, including initiation of the loan repayment
process.
Cause: Internal controls do not appear to be in place to accurately and timely identify the relevant
dates for reporting to NSLDS.
Repeat finding
From Prior Year:
No
Context: Out of the 36 sample of students tested, 23 students had at least one incorrect reporting of
Campus‐Level and Program‐Level requirements and/or considered to be reported late. Nonstatistical
sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
status date changes are being reported to NSLDS.
Views of Responsible Officials:
We agree with the finding.
2023‐003 U.S. Department of Education
Student Financial Aid Cluster (FAL # 84.268, 84.063)
Special Test: Enrollment Reporting
Material Weakness in Internal Control over Compliance
Criteria: The National Student Loan Data System (NSLDS) is the national database of information about
loans and grants awarded to students.
Institutions are required to report enrollment information under the Pell grant and the Direct
and FFEL loan programs via the NSLDS (OMB No. 1845‐0035), although FFEL loans are no longer
made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that
would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR
682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)).
The administration of the Title IV programs depends heavily on the accuracy and timeliness of
the enrollment information reported by institutions. Institutions must review, update, and
certify student enrollment statuses, program information, and effective dates that appear on
the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website which the financial aid administrator can access for the
auditor.
Institutions are also responsible for accurately reporting all Campus‐Level Record data elements
including OPEID number, enrollment effective data, enrollment status, and certification date.
Institutions are responsible for accurately reporting all Program‐Level record data including CIP
year, credential level, published program length measurement, published program length,
program begin date, program enrollment status, and program enrollment effective date. Condition: Various discrepancies were noted between the District and NSLDS for both the Campus‐Level
and Program‐Level requirements. Further some of the data provided was provided later than
the required timelines established.
Questioned
Costs: None
Effect: Untimely and inaccurate reporting of student enrollment status does not allow the Department
of Education to properly track and monitor students, including initiation of the loan repayment
process.
Cause: Internal controls do not appear to be in place to accurately and timely identify the relevant
dates for reporting to NSLDS.
Repeat finding
From Prior Year:
No
Context: Out of the 36 sample of students tested, 23 students had at least one incorrect reporting of
Campus‐Level and Program‐Level requirements and/or considered to be reported late. Nonstatistical
sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
status date changes are being reported to NSLDS.
Views of Responsible Officials:
We agree with the finding.
2023‐003 U.S. Department of Education
Student Financial Aid Cluster (FAL # 84.268, 84.063)
Special Test: Enrollment Reporting
Material Weakness in Internal Control over Compliance
Criteria: The National Student Loan Data System (NSLDS) is the national database of information about
loans and grants awarded to students.
Institutions are required to report enrollment information under the Pell grant and the Direct
and FFEL loan programs via the NSLDS (OMB No. 1845‐0035), although FFEL loans are no longer
made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that
would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR
682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)).
The administration of the Title IV programs depends heavily on the accuracy and timeliness of
the enrollment information reported by institutions. Institutions must review, update, and
certify student enrollment statuses, program information, and effective dates that appear on
the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website which the financial aid administrator can access for the
auditor.
Institutions are also responsible for accurately reporting all Campus‐Level Record data elements
including OPEID number, enrollment effective data, enrollment status, and certification date.
Institutions are responsible for accurately reporting all Program‐Level record data including CIP
year, credential level, published program length measurement, published program length,
program begin date, program enrollment status, and program enrollment effective date. Condition: Various discrepancies were noted between the District and NSLDS for both the Campus‐Level
and Program‐Level requirements. Further some of the data provided was provided later than
the required timelines established.
Questioned
Costs: None
Effect: Untimely and inaccurate reporting of student enrollment status does not allow the Department
of Education to properly track and monitor students, including initiation of the loan repayment
process.
Cause: Internal controls do not appear to be in place to accurately and timely identify the relevant
dates for reporting to NSLDS.
Repeat finding
From Prior Year:
No
Context: Out of the 36 sample of students tested, 23 students had at least one incorrect reporting of
Campus‐Level and Program‐Level requirements and/or considered to be reported late. Nonstatistical
sampling was used.
Recommendation:
We recommend that management update their control processes to ensure that the proper
status date changes are being reported to NSLDS.
Views of Responsible Officials:
We agree with the finding.