Compliance Requirement: Reporting
Criteria
Per 34 CFR 668, 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. In addition, CFR 200.303 requires nonfederal entities to, among
other things, establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non‑Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition Found
The University did not have controls appropriately designed to ensure timely reporting of disbursements to
the Department of Education Common Origination and Disbursement (COD) system. Specifically, during
our testing, we selected a sample of 40 students to recalculate the days between disbursements and the
reporting of disbursements to COD. Three of our selections (two graduate students and one undergraduate
student) were not submitted within the required 15-day window. These students were part of a population
that the University attempted to submit to COD timely but, due to system errors, that submission was not
transmitted. The University later discovered this and resubmitted the information 4 days after the due date.
The University’s controls were not designed to ensure those errors were resolved timely.
Cause and Effect
The University did not design its controls to ensure error reports with the COD were resolved on a timely
basis to ensure disbursements were reported on a timely basis. Each of the errors were resolved and
information was ultimately reported to the COD, however, not within the 15-day window.
Repeat Finding
This finding is not a repeat finding in the immediately prior audit.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
We recommend the University improve related control to ensure disbursements are reported to the
Department of Education within the 15-day requirement.
Views of Responsible Officials
The University agrees with the condition reported. The responsible department did initiate the student
report transmittal to the COD, however a system error prevented it from reaching the COD. The University
updated its control processes to ensure the COD confirms receipt of the student report transmittals to
mitigate such errors for future reporting.
Compliance Requirement: Reporting
Criteria
Per 34 CFR 668, 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. In addition, CFR 200.303 requires nonfederal entities to, among
other things, establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non‑Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition Found
The University did not have controls appropriately designed to ensure timely reporting of disbursements to
the Department of Education Common Origination and Disbursement (COD) system. Specifically, during
our testing, we selected a sample of 40 students to recalculate the days between disbursements and the
reporting of disbursements to COD. Three of our selections (two graduate students and one undergraduate
student) were not submitted within the required 15-day window. These students were part of a population
that the University attempted to submit to COD timely but, due to system errors, that submission was not
transmitted. The University later discovered this and resubmitted the information 4 days after the due date.
The University’s controls were not designed to ensure those errors were resolved timely.
Cause and Effect
The University did not design its controls to ensure error reports with the COD were resolved on a timely
basis to ensure disbursements were reported on a timely basis. Each of the errors were resolved and
information was ultimately reported to the COD, however, not within the 15-day window.
Repeat Finding
This finding is not a repeat finding in the immediately prior audit.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
We recommend the University improve related control to ensure disbursements are reported to the
Department of Education within the 15-day requirement.
Views of Responsible Officials
The University agrees with the condition reported. The responsible department did initiate the student
report transmittal to the COD, however a system error prevented it from reaching the COD. The University
updated its control processes to ensure the COD confirms receipt of the student report transmittals to
mitigate such errors for future reporting.
Compliance Requirement: Reporting
Criteria
Per 34 CFR 668, 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. In addition, CFR 200.303 requires nonfederal entities to, among
other things, establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non‑Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition Found
The University did not have controls appropriately designed to ensure timely reporting of disbursements to
the Department of Education Common Origination and Disbursement (COD) system. Specifically, during
our testing, we selected a sample of 40 students to recalculate the days between disbursements and the
reporting of disbursements to COD. Three of our selections (two graduate students and one undergraduate
student) were not submitted within the required 15-day window. These students were part of a population
that the University attempted to submit to COD timely but, due to system errors, that submission was not
transmitted. The University later discovered this and resubmitted the information 4 days after the due date.
The University’s controls were not designed to ensure those errors were resolved timely.
Cause and Effect
The University did not design its controls to ensure error reports with the COD were resolved on a timely
basis to ensure disbursements were reported on a timely basis. Each of the errors were resolved and
information was ultimately reported to the COD, however, not within the 15-day window.
Repeat Finding
This finding is not a repeat finding in the immediately prior audit.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
We recommend the University improve related control to ensure disbursements are reported to the
Department of Education within the 15-day requirement.
Views of Responsible Officials
The University agrees with the condition reported. The responsible department did initiate the student
report transmittal to the COD, however a system error prevented it from reaching the COD. The University
updated its control processes to ensure the COD confirms receipt of the student report transmittals to
mitigate such errors for future reporting.
Compliance Requirement: Reporting
Criteria
Per 34 CFR 668, 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. In addition, CFR 200.303 requires nonfederal entities to, among
other things, establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non‑Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition Found
The University did not have controls appropriately designed to ensure timely reporting of disbursements to
the Department of Education Common Origination and Disbursement (COD) system. Specifically, during
our testing, we selected a sample of 40 students to recalculate the days between disbursements and the
reporting of disbursements to COD. Three of our selections (two graduate students and one undergraduate
student) were not submitted within the required 15-day window. These students were part of a population
that the University attempted to submit to COD timely but, due to system errors, that submission was not
transmitted. The University later discovered this and resubmitted the information 4 days after the due date.
The University’s controls were not designed to ensure those errors were resolved timely.
Cause and Effect
The University did not design its controls to ensure error reports with the COD were resolved on a timely
basis to ensure disbursements were reported on a timely basis. Each of the errors were resolved and
information was ultimately reported to the COD, however, not within the 15-day window.
Repeat Finding
This finding is not a repeat finding in the immediately prior audit.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
We recommend the University improve related control to ensure disbursements are reported to the
Department of Education within the 15-day requirement.
Views of Responsible Officials
The University agrees with the condition reported. The responsible department did initiate the student
report transmittal to the COD, however a system error prevented it from reaching the COD. The University
updated its control processes to ensure the COD confirms receipt of the student report transmittals to
mitigate such errors for future reporting.