Finding Text
Federal Program Information: Federal Pell Grant Program (ALN#: 84.063)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System
Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant 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.
An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “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. 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 University failed to timely report Pell payment data for 1 of 25 selections.
Cause: Insufficient internal control and administrative oversight with respect to COD reporting.
Effect or Possible Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 out of 25 Pell disbursement records selected for testing, the disbursement was not reported to COD within 15 calendar days.
Identification of Repeat Finding: There was a similar finding, 2023-001, identified during the
prior year.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD.
Views of Responsible Officials: The student that was not reported within 15 calendar days was before we had a process in place to prevent this issue from happening. As a result of this finding, Financial Aid and Accounting are reconciling weekly to mitigate this issue.