Finding Text
Finding 2025-002 Student Financial Aid Cluster Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268) Criteria: Institutions are required to submit Direct Loan and Pell Grant origination records and disbursement records to the Common Origination and Disbursement System (COD). Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for payment. An institution follows up with a disbursement record for that student. The disbursement record reports the actual disbursement date and the amount of the disbursement. Additionally, the enrollment date, verification status code, if applicable, and cost of attendance should be accurately reported to COD. Condition: Our review of the COD reports for 40 students, yielded 24 instances in which the Cost of Attendance did not match the records of WCCC. We noted an additional 5 instances in which the amount reported to COD matched the records within Anthology, however, as noted in finding 2025-001, the amounts within Anthology were noted to be miscalculated. Cause: Controls were not in place to ensure that accurate information was being submitted to COD. Effect: Failure to accurately report cost of attendance, disbursement amounts and disbursement dates to the COD can cause errors in reporting student aid eligibility, violations of federal cash management requirements and creates reconciliation discrepancies between the Department of Ed’s system and the institution’s records. Repeat Finding: This is a not a repeat finding. Questioned costs: Unknown Recommendation: We recommend that WCCC strengthen its internal controls over Title IC reporting to the Common Origination and Disbursement System by establishing a formal process to verify the accuracy of cost of attendance, disbursement amounts and disbursement dates prior to submission to COD and by developing monitoring reports and maintaining documentation of reviews and corrections to demonstrate compliance with the federal regulations. View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.