Finding Text
Common Origination and Disbursement (COD) Reporting and Reconciliations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Pell Grants Federal Award Identification #: 2023-2024 Financial Aid Year Condition: The dates and amounts that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Reconciliations between COD and disbursements to student accounts were not performed regularly. Criteria: 34 CFR 668.164, 34 CFR 685.300(b)(5), 34 CFR 685.301(a)(2) and 34 CFR 690.83 Questioned Costs: $0 Context: Out of 22 students tested, 20 students did not have the correct disbursement dates for both Fall and Spring terms. Cause: Reconciliations of College records to COD were not completed regularly so the errors between the two systems were not identified in a timely manner. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: 2022-006, 2023-010 Recommendation: We recommend the College implement procedures to reconcile monthly FDL and Pell disbursements to student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.