Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them f...
Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (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 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. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must 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 statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In testing the origination and disbursement data, key items to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. During our test work over the key items on origination records as reported on COD, KPMG identified the following: • 6 of the 40 students selected for test work had incorrect academic start or end dates that did not agree to the College’s records. None of the items that were exceptions described above resulted in the College over awarding students for the current fiscal year. Cause The condition resulted from the College Student Financial Aid Operations Department not reporting updated information to the COD System when changes were made to enrollment dates of the students identified due to the College not having an adequate internal control process. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to reporting key items to the COD System and update key fields as information may change during the awarding process to ensure that they agree to the College’s records. Views of Responsible Officials Responsible Individual: Russell Romandini, Director of Student Financial Aid Services, Student Financial Services Contact Information: rromandini@berklee.edu , 617-747-2505 Management concurs with the recommendation. Berklee will enhance internal controls over the reporting of key data to the COD system. Designated staff in the Student Financial Aid Operations Department and Office of the Registrar has developed reports and implemented a recurring review process comparing enrollment and academic year dates in PowerFAIDS to Berklee’s registration records. This review will be performed at relevant intervals to be sure data mismatches are resolved by the end of the academic year processing cycle. These intervals occur towards the end of academic year processing (summer semester for campus; spring and summer terms for the online program) as these are the academic periods that generate the most enrollment changes, and with it, academic year date fluctuations. Any differences identified will be updated in PowerFAIDS and COD as necessary and in a timely manner to ensure ongoing data alignment and accuracy between the COD system and institutional records. Supervisory oversight by the Director of Student Aid Operations will include review and sign off to ensure the enhanced procedures are consistently followed by the Operations team to remediate the risk of any future findings. Expected Implementation Completed: May 31, 2026 Status of Completion: In Process