Finding Text
Federal Agency: Department of Education
Federal Program: Student Financial Assistance Cluster
ALN Numbers: 84.268 – Federal Direct Loan Program
Award Period: July 1, 2023 through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: 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.
Condition: During our testing, we noted 10 out of the 40 student's disbursement date per the Seminary’s record did not match the date reported to COD.
Questioned Costs: None
Context: During our testing, it was noted the Seminary does not have a process in place to ensure accurate reporting of disbursement dates to COD based on the regulations set forth by the Department of Education.
Cause: The Seminary does not have a process in place to accurately report the date of disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: No
Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.