Finding Text
Criteria or Specific Requirement
Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records to the COD ("Common Origination and Disbursement") system. 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 the disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected disbursement date.
Condition
Of the 40 disbursements selected for COD reporting testing, one disbursement was reported late compared to the required 15-day threshold.
Cause
At that time, the School was transitioning to a new system platform. As such, disbursement was not reported within the 15-day required timeframe.
Effect
As the change in status was not reported within the specified time or not reported at all, COD data was not up to date.
Questioned Costs
None noted.
Context
The auditor selected 40 students to test COD reporting and examined if the School reported the disbursement within 15 days.
Identification as a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend the School implement a policy where the disbursements are submitted within the 15 days.