Finding Text
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The dates and amounts that Pell and FDL awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD).
Criteria: 34 CFR 668.164(a)
Questioned Costs: $0
Context: 4 of 60 students tested had COD loan and Pell disbursement date errors ranging from 7 to 15 days, including one student who did not have the correct amount of Pell reported on COD compared to what was accurately disbursed on the student account. The students that COD allowed corrections to occur have been corrected.
Cause: Reconciliations are completed by the third party administrator with the third party’s system of disbursement. Adjustments that occurred on the student account did not always get transferred to the third party system and were not identified in the reconciliation process.
Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and amounts with the University’s student information system.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.