Finding Text
Criteria According to 2024-2025 Federal Student Aid Handbook, Volume 4, Chapter 2, Reporting Disbursements Within 15 Days Schools must submit Direct Loan, Pell, and TEACH Grant disbursement records to the COD System no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. See Federal Register Volume 88, Number 120, June 23, 2023. The Department considers that Title IV funds are disbursed on the date that schools (a) credit those funds in their general ledger or any subledger to a student’s account or (b) pay those funds to a student or parent directly. Title IV aid is disbursed even if schools use their own funds in advance of receiving program funds from the Department. Failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 32 students, out of a sample of 40, were not reported within the required timeframe by 12-19 days. Cause The College maintains established policies and procedures to ensure that disbursement records are reported to the Department of Education through the COD system within the required fifteen-calendar-day timeframe. In this instance, however, staffing transitions within the financial aid department resulted in a delay of two to three weeks in submitting the records. Effect The College did not report Direct Loan disbursements to COD within the required time frame. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 32 students, or 80% of our sample, were not reported to COD within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that management provide adequate cross-training for staff processing Direct Loan disbursements to ensure all Direct Loans are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.