Finding Text
Finding 2025-001 - Reporting: Financial Reporting - Student Financial Assistance Cluster, ALN 84.268 and 84.063, June 30, 2025 Award Year, U.S. Department of Education Criteria or Specific Requirement Institutions submit Direct Loan, Pell Grant, and TEACH Grant origination records to the Common Origination and Disbursement (“COD”) 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 student disbursement data. (November 2025 OMB Compliance Supplement page 5-3-24) Condition Three out of forty disbursements tested were reported late to COD, one was 3 days late and two were 23 days late. This was not a statistically valid sample. Cause The College was closed when one disbursement was made, and two disbursements were off-cycle disbursements which resulted in delays in reporting the disbursements to COD. Effect A student’s enrollment status determines eligibility for in-school status, deferment, grace periods, and repayments, as well as the government’s payment of interest subsidies. The notification of student status changes to NSLDS will cause a student to enter into a grace period and determine a repayment date and, therefore, accurate and timely notification of student status to NSLDS is important. Questioned Costs None Identification as a Repeat Finding Not a repeat finding. Recommendation Management should implement a process or tracking mechanism to create reminders of COD reporting due dates when disbursements are made, particularly for off-cycle disbursements or disbursements during school breaks. Views of Responsible Officials and Corrective Actions See Corrective Action Plan.