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Federal Program Information: Direct Student Loans Program (ALN 84.268) Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “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. 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. Key items to test on origination records for the fiscal year are: award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: For two of the students selected for origination testing, we identified variances in the Cost of Attendance ("COA") reported to the COD system compared to the COA recorded in the University's system used for awarding Title IV aid to the student. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with key origination reporting requirements. No instances of over awards were noted. Questioned Costs: None. Context: 2 out of 40 students selected for testing appeared to have incorrect reported COA. Identification as a Repeat Finding: There were no similar findings identified in the prior year. Recommendation: We recommend the University enhance its procedures over COD origination reporting requirements to ensure students are not over awarded. Views of Responsible Officials: Financial Aid will originate direct loans at least one week prior to the scheduled disbursement date. For large origination files at semester starts, financial aid administrators will run simulation originations to work through origination and/or disbursement rejections prior to sending real originations at least one month prior to semester starts.