Finding Text
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the Institute to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 3 instances tested had incorrect unsubsidized loan disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None Context: 3 instances of disbursements tested had incorrect unsubsidized disbursement dates reported to COD. Cause: The Institute does not have a process in place to accurate report Unsubsidized Loan disbursements to COD. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the Institute evaluate its procedures and policies around reporting Unsubsidized Loan disbursements to COD to ensure that student information is reported accurately. Views of Responsible Officials: There is no disagreement with the audit finding.