Finding Text
2025–005 Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853, P063P241853, P007A242813, P033A24813; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: Per U.S. Department of Education guidelines for COD reporting, institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition/Context: During our testing of COD reporting, the following was noted: 10 disbursements out of a sample of 40 disbursements tested were not applied within 15 days to COD. 3 disbursements out of a sample of 40 disbursements tested, the disbursement date in COD did not match the actual date of disbursement on the student’s ledger card. Questioned costs: No. Cause: During our testing, it was noted that the College did not have the proper procedures and review in place to ensure that disbursements are reported accurately and timely to COD. Effect: Inaccurate dates and late reporting to COD regarding student disbursements. Repeat Finding: No. Recommendation: We recommend that the College review its reporting procedures to COD to ensure disbursements are reported timely and accurately to be in compliance with regulations. Views of responsible officials: Please refer to the attached corrective action plan.