Finding Text
Common Origination & Disbursement Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: N/A Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance; Noncompliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR § 685.301(d)(2) and 34 CFR § 690.83(a)(2), institutions are required to report disbursement information to the Common Origination & Disbursement (COD) System no later than 15 days after making a Title IV disbursement or becoming aware of a change to previously reported disbursement data. Institutions must ensure that all disbursement dates reported to COD accurately reflect the actual date the disbursement was made or became ready for delivery to the student. Condition: We noted instances of late or inaccurate reporting to COD. Questioned costs: None Context: Pell Disbursement dates for 38 of 40 awards were inaccurately reported in COD, with 15 reported outside the 15‑day timeframe. This occurred because disbursements were posted one day prior to sending the COD file, causing timing discrepancies in reported dates. Cause: Human error within the school’s system and processing controls. Effect: Issues with untimeliness reporting could result with potential non-compliance. Repeat Finding: No Recommendation: We recommend the District evaluate its procedures and policies around reporting Pell 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.