Finding Text
Finding 2025-003 – Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.063 U.S. Department of Education Student Financial Aid Cluster – Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Federal regulations require institutions to maintain accounting records that accurately reflect the receipt and disbursement of Title IV funds on a current basis and provide a clear audit trail from drawdown through disbursement. Condition: In our nonstatistical sample of 40 students, it was noted for 30 individuals that the institution reported disbursements to the Common Origination and Disbursement (COD) system on dates that did not agree to the dates the disbursements were recorded in the general ledger. Context: Differences noted were between 1 and 5 days, except for one student where the difference was 8 days. Effect: The University’s accounting records did not consistently support the disbursement dates reported to COD. Questioned Costs: None Cause: Ottawa University did not have proper processes and related controls in place to complete COD documentation in the COD system on dates that agreed to the dates the disbursements were recorded in the general ledger. Indication As Repeat Finding: Not a repeat finding. Recommendation: The University should ensure that disbursement dates reported to COD agree with the actual disbursement dates recorded in the general ledger or are fully supported by subsidiary records. Views Of Responsible Officials (Unaudited): Student Financial Aid and Accounts Receivable will work in coordination to sync the process of importing files and posting to accounts on the same day. Our new ERP has streamlined reporting to COD and catches and corrects any date discrepancies between the two systems. This finding was directly related to the migration from our old system and the disruption of data flow. Additionally, a review for matching COD disbursement dates will now be included during the monthly reconciliation process moving forward as a second layer of quality control. Anticipated Completion Date: June 30, 2026 Contact Person: Mary Reed, Director of Financial Aid & Advising