Finding Text
Common Origination and Disbursement (COD) Reporting and Reconciliations Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The dates and amounts that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Reconciliations between COD and disbursements to student accounts were not performed regularly.
Criteria: 34 CFR 668.164, 34 CFR 685.300(b)(5), 34 CFR 685.301(a)(2) and 34 CFR 690.83
Questioned Costs: $0
Context: Two students of 39 tested had COD loan disbursement date errors ranging from 25-153 days, both in the Fall and Spring terms. One student out of 39 tested had COD Pell disbursement date error of 15 days.
Cause: Reconciliations of College records to COD were not completed regularly so the errors between the two systems were not identified in a timely manner.
Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans.
Identification as repeat finding, if applicable: 2022-006
Recommendation: We recommend the College implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.