Finding Text
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033
Compliance Requirement(s): Reporting – COD Reporting
Significant Deficiency in Internal Control
Criteria: 34 CFR 685.215 states that Institutions are responsible for submitting a loan award record to the Department of Education’s Common Origination and Disbursement (COD) System and receive an accepted response prior to disbursing the loan. The institution is also responsible for implementing an effective control over this process.
Condition: During our testing of compliance for COD Reporting, it was noted that there was no documented control over the Student Account Statement (SAS) reconciliation that is performed after loans have been submitted to COD and disbursed.
Cause: The College did not have a documented control over the SAS reconciliation process.
Effect: Without a secondary review and approval, there is a possibility that the COD Reporting could be incorrect.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 3 monthly SAS reconciliations out 12 monthly reconciliations.
Repeat Finding from Prior Year(s): No
Recommendation: The College should review its current controls over COD Reporting and SAS reconciliations and ensure those controls are properly documented.
Views of Responsible Officials: Management agrees with the finding. The Financial Aid Office will retain documentation of the control over the SAS reconciliation process.