Finding Text
2024-003: Reporting: Common Origination and Disbursement
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2023 through June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or specific requirement: The Department of Education requires institutions 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.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain
internal controls designed to reasonably ensure compliance with federal laws, regulations, and program
compliance requirements.
2024-003: Reporting: Common Origination and Disbursement (Continued)
Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of
noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported
within the required 15 days.
Cause: The University has not implemented precise review controls to ensure compliance with
accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation
could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: Yes, 2023-005
Recommendation: We recommend that the Student Financial Aid department work to ensure
disbursements are reported to COD within 15 days of the disbursement date and that disbursements
date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.