Finding Text
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.379 Award Period: August 1, 2024 through July 31, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the Institute 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 that the College's internal controls over COD reporting were not operating effectively. For 17 out of 32 disbursements, CLA noted that the COD disbursement date did not match the date the student was disbursed per their student account detail. For 15 out of 32 disbursements, CLA noted that the COD disbursement date was before the disbursement date per each student's account detail. For 5 out of 32 disbursements, the applied date was not reported timely and was outside of the allowed 15-day period after disbursing the student's award. Questioned Costs: None Context: During our testing, we noted the College did not have proper procedures in place to verify the dates sent to COD are timely and accurate. Cause: The College does not have a process in place to accurate report Unsubsidized Loan disbursements to COD. 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: No Recommendation: We recommend the College evaluate its procedures and policies around reporting to COD to ensure that student information is reported accurately. Views of Responsible Officials: There is no disagreement with the audit finding.