Finding Text
2025-001: Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster ALN Numbers: 84.268 – Federal Direct Loan Program Award Period: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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. Condition: During our testing, we noted 9 out of the 29 student's disbursement date per the Seminary’s record did not match the date reported to COD. Questioned Costs: None Context: During our testing, it was noted the Seminary does not have a process in place to ensure accurate reporting of disbursement dates to COD based on the regulations set forth by the Department of Education. Cause: The Seminary does not have a process in place to accurately report the date of disbursements. 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: Yes – See 2024-001 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.