Finding Text
Finding 2025-003 – COD Disbursement Records Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Reporting Criteria: In accordance with subpart G of the General Provisions regulations in 34 CFR part 668, an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement reports to COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), funds are disbursed on the date that the institution: (a) credits those funds to a student’s account in the institution’s general ledger; or (b) pays those funds to a student directly. Funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Two batches of Unsubsidized Direct Loan disbursement records did not agree to the applicable students’ accounts. Corrections were not made with COD to remedy these discrepancies. Cause of Condition: At the time of submissions of the disbursement records to COD, the COD system was experiencing processing issues, and these batches were not posted by COD until a number of days after the attempted submissions. This caused the incorrect dates to be posted. The College did not submit maintenance files to correct these dates to agree with students’ accounts. Effect: Failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Questioned Costs: No questioned costs. Perspective Information: N/A Recommendation: We recommend the College review COD disbursement records after each disbursement to ensure the date agrees with student account records.