Finding Text
2025 - 001 – Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 Award Period: 7/1/24-6/30/25 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.83(b)(2) and 34 CFR 685.309 states institutions must report the disbursement dates and amounts to the COD within 15 days of disbursing Pell and Direct Loan funds to students. Condition: One disbursement was not reported to COD within the required timeframe. Questioned Costs: None. Context: During our testing, 1 student out of a sample of 40 had a disbursement that was not reported to COD within the required 15-day timeframe. Cause: The University's process to ensure timely COD reporting was not functioning properly. Effect: The University did not report to the COD within the required timeframe. Repeat Finding: No. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Views of Responsible Officials: There is no disagreement with the audit finding.