Finding 1182816 (2025-002)

Criteria or specific requirement: The Department of Education requires the College 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. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Questioned costs: None. Context: We did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not maintain documentation of a control in place to ensure timely and accurate reporting to COD. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes, 2024-005. Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Views of responsible officials: There is no disagreement with the audit finding.