Finding Text
Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268
Special Tests and Provisions – Common Origination and Disbursement (COD) Reporting
Material Weakness in Internal Control over Compliance
Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. 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: During our testing of the information submitted to COD we noted 13 students out of the 40 tested where the disbursement date per the College’s records and the processing date at COD fell outside the mandatory 15-day reporting window.
Cause: The College had issues with the student information system as they prepared to switch to a new information system that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported.
Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education.
Questioned Costs: None reported
Context/Sampling: The College disbursed Federal financial aid to approximately 655 students in the 2023-2024 school year. A non-statistical sample of 40 students was selected for testing.
Repeat Finding: Yes
Auditor’s recommendation: The College should implement additional processes to review, update, and verify that student disbursements are reported to COD accurately and timely.
Management’s response: The issue related to the Common Origination and Disbursement (COD) disbursement files continued to be an issue with our old Student Information System (SIS), Anthology. As of July 1, 2024 the College has moved to a new SIS, FOCAL. In addition, we moved to a standalone financial aid system, PowerFaids, that integrates with FOCAL. PowerFaids does not allow disbursement unless the Common Origination and Disbursement file from EdExpress is marked accordingly. Moving forward, disbursement files from COD will be reviewed daily and any disbursement records found to have errors will be resolved immediately. This will prevent future disbursement date errors with COD.