Finding Text
2025-003 – Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P231818; P063P241818 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Department of Education regulations require institutions to report Pell Grant and Direct Loan disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursement (34 CFR 690.83(b)(2) and 34 CFR 685.309). Condition: During our testing, we noted the University did not have adequate internal controls to ensure timely reporting to the COD. Questioned costs: None. Context: During our testing, we noted 6 out of 18 Pell disbursements were not reported within the 15 days required to the COD. Cause: The University’s procedures for timely reporting Pell Grant disbursements to COD were not functioning effectively. Effect: The University is not in compliance with COD reporting requirements. Repeat finding: No. Recommendation: We recommend the University review and enhance its policies and procedures related to COD reporting to ensure all disbursement information is reported accurately and within required timeframes. Views of responsible officials: There is no disagreement with the audit finding.