2024-005: Reporting – Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Number and Year: P007A215801 (March 25, 2021 - August 31, 2027), P033A215801 (July 1, 2021 - August 31, 2027), P063P213807 (March 23, 2021 - August 31, 2027), P268K223807 (January 1, 2021 - July 31, 2043) Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance- From the 2022-23 FSA Handbook: to be in compliance with reporting disbursements and disbursement adjustments within 15 days. The date funds are credited to a student’s account in the institution’s general ledger or any subledger of the general ledger or paid to a student directly is the disbursement date the financial aid office reports to COD. The Common Origination and Disbursement (COD) additional requirements are: (1) Schools must use the COD system to request and receive federal student aid funds, including Direct Loans, Pell Grants, and Campus-Based aid programs. Schools must ensure that all disbursements of federal student aid are made through the COD system. (2) Schools must reconcile their records with the COD system to ensure that all disbursements are accurately reported and recorded. (3) Schools must comply with COD reporting requirements, including reporting disbursements, adjustments, and cancellations in a timely and accurate manner. Condition: During audit procedures, we noted the following items were incorrectly reported to the COD: Fall 2023 • For 4 of 16 student disbursements tested, the PELL disbursement date did not match between COD and the student ledgers. • For 4 of 16 student disbursements tested, the PELL applied dates did not fall within the 15 day requirement from the disbursement date. • For 2 of 16 student disbursements tested, the PELL disbursement amount did not match between COD and the student ledgers. • For 1 of 15 student disbursements tested, the Subsidized Direct Loan applied date did not fall within the 15 day requirement from the disbursement date. • For 2 of 8 student disbursements tested, the Unsubsidized Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date. Spring 2024 • For 3 of 16 student disbursements tested, the PELL disbursement dates did not match between COD and the student ledgers. • For 3 of 16 student disbursements tested, the PELL applied dates did not fall within the 15 day requirement from the disbursement date. • For 1 of 16 student disbursements tested, the PELL disbursement amount did not match between COD and the student ledgers. • For 3 of 15 student disbursements tested, the Subsidized Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date. • For 1 of 8 student disbursements tested, the Unsubsidized Direct Loan applied date did not fall within the 15 day requirement from the disbursement date. Summer 2024 • For 1 of 16 student disbursements tested, the PELL disbursement date did not match between COD and the student ledgers. • For 1 of 16 student disbursements tested, the PELL applied dates did not fall within the 15 day requirement from the disbursement date. • For 1 of 16 student disbursements tested, the PELL disbursement amount did not match between COD and the student ledgers. • For 2 of 15 student disbursements tested, the Subsidized Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date. • For 3 of 8 student disbursements tested, the Unsubsidized Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date. • For 1 of 1 student disbursements tested, the Parent Plus Direct Loan applied date did not fall within the 15 day requirement from the disbursement date. Questioned Costs: None. Context: During audit procedures, we noted the following items: Fall 2023 • For 4 of 16 student disbursements tested, the PELL disbursement date per the student ledger compared to COD was as follows: a. 9/1/23 per student ledger and 4/5/24 per COD. b. 9/22/23 per student ledger and 2/15/24 per COD c. 11/10/23 per student ledger and 2/2/24 per COD d. 11/16/23 per student ledger and 6/21/24 per COD • For 4 of 16 student disbursements tested, the PELL applied date per the student ledger compared to COD was as follows: a. 9/1/23 per student ledger and 4/18/24 per COD. b. 9/22/23 per student ledger and 7/8/24 per COD c. 11/10/23 per student ledger and 2/12/24 per COD d. 11/16/23 per student ledger and 7/9/24 per COD • For 2 of 16 student disbursements tested, the PELL disbursement amount per the student ledger compared to COD was as follows: a. $925 per student ledger and $1,848 per COD b. $924 per student ledger and $1,849 per COD • For 1 of 15 student disbursements tested, the Subsidized Direct Loan applied date per the student ledger compared to COD was as follows: a. 11/10/23 per student ledger and 12/12/23 per COD • For 2 of 8 student disbursements tested, the Unsubsidized Direct Loan applied date per the student ledger compared to COD was as follows: a. 9/15/23 per student ledger and 10/2/23 per COD b. 11/10/23 per student ledger and 12/12/23 per COD Spring 2024 • For 3 of 16 student disbursements tested, the PELL disbursement date per the student ledger compared to COD was as follows: a. 2/2/24 per student ledger and 6/21/24 per COD for all 3 students • For 3 of 16 student disbursements tested, the PELL applied date per the student ledger compared to COD was as follows: a. 2/2/24 per student ledger and 11/15/24 per COD for 2 students b. 2/2/24 per student ledger and 7/9/24 per COD for 1 student • For 1 of 16 student disbursements tested, the PELL disbursement amount per the student ledger compared to COD was as follows: a. $1,849 per student ledger and $2,773 per COD • For 3 of 15 student disbursements tested, the Subsidized Direct Loan applied date per the student ledger compared to COD was as follows: a. 3/1/24 per student ledger and 4/17/24 per COD for all 3 students • For 1 of 8 student disbursements tested, the Unsubsidized Direct Loan applied date per the student ledger compared to COD was as follows: a. 3/1/24 per student ledger and 4/17/24 per COD Summer 2024 • For 1 of 16 student disbursements tested, the PELL disbursement date per the student ledger compared to COD was as follows: a. 6/21/24 per student ledger and 7/3/24 per COD • For 1 of 16 student disbursements tested, the PELL applied date per the student ledger compared to COD was as follows: a. 6/21/24 per student ledger and 7/23/24 per COD • For 1 of 16 student disbursements tested, the PELL disbursement amount per the student ledger compared to COD was as follows: a. $372 per student ledger and $1 per COD • For 2 of 15 student disbursements tested, the Subsidized Direct Loan applied date per the student ledger compared to COD was as follows: a. 6/21/24 per student ledger and 7/9/24 per COD b. 7/3/24per student ledger and 7/23/24 per COD • For 3 of 8 student disbursements tested, the Unsubsidized Direct Loan applied date per the student ledger compared to COD was as follows: a. 6/21/24 per student ledger and 7/9/24 per COD for 2 students b. 7/3/24 per student ledger and 1/31/25 per COD for 1 student • For 1 of 1 student disbursements tested, the Parent Plus Direct Loan applied date per the student ledger compared to COD was as follows: a. 8/21/24 per student ledger and 1/31/25 per COD Cause: Employee turnover during the academic year caused this process to not be completed accurately. Effect: The University is not complying with federal requirements of reporting and information-sharing requirements established by the Department of Education. Repeat Finding: Yes – 2023-006. Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.