Finding Text
2024-006 – Common Origination and Disbursement (COD) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.063 and 84.268; Award Numbers P063P231644, P063Q231644 and P268K241644. Criteria. The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. Cause. The College did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.