FAC Explorer

Finding 1237695 (2026-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2026
Accepted
2026-09-28
Audit: 412634
Organization: Mid-America Christian University (OK)
Auditor: CAPINCROUSE LLC

AI Summary

  • Core Issue: Disbursement dates reported to COD for Pell and Federal Direct Loans do not match actual disbursement dates on student accounts.
  • Impacted Requirements: Compliance with 34CFR 668.164(a) is compromised, potentially affecting student loan interest periods and lifetime Pell limits.
  • Recommended Follow-Up: Implement procedures to align COD reporting with actual disbursement dates and update monthly reconciliations by date and amount.

Finding Text

Common Origination and Disbursement (COD) Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants, 84.268 Federal Direct Student Loans Federal Award Identification #: 2025-2026 Financial Aid Year Condition: The disbursement dates in COD did not always agree with the actual dates of disbursement on the student account when reporting disbursement records for Pell and Federal Direct Loans (FDL) to COD. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: 20 of 40 students tested had COD loan and Pell disbursement date errors ranging from 6-35 days. There were no errors in the amounts reported, just the date of disbursement. Cause: The student information system was not set up to sync actual disbursement dates from the student account to COD. Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit, however, there was no indication of this. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. We also recommend that the University update monthly reconciliations to be by date as well as amount. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: Mid-America Christian University (MACU) has revised its Title IV disbursement and ledger posting workflow to ensure alignment between internal financial records and Common Origination and Disbursement (COD) reporting. Previously, student ledger postings were dated using the G5 deposit date rather than the COD disbursement date. To resolve this issue and prevent future recurrence: 1. Alignment of Disbursement Dates: MACU has updated its workflow in PowerFAIDS and the Jenzabar to ensure disbursements are posted to student accounts using the disbursement date reported to COD rather than the /G5 drawdown/deposit date. 2. Timely COD Reporting: Actual disbursement records generated in PowerFAIDS will be transmitted to the COD System within 15 calendar days of the actual disbursement date, in full compliance with 34 CFR 668.164. 3. Reconciliation & Controls: The Financial Aid Office and Bursar Office will perform a monthly three-way reconciliation between G5 drawdown records, PowerFAIDS disbursement data (alongside student ledgers), and COD actual disbursement records to guarantee date consistency and compliance across all systems. Person Responsible for Corrective Action Plan: Bobbie Spurgeon-Harris, Executive Vice-President and Chief and Dean Meadows, VP / CFO Anticipated Date of Completion: 10/01/2026

Categories

Student Financial Aid Reporting Significant Deficiency

Other Findings in this Audit

  • 1237692 2026-002
    Material Weakness Repeat
  • 1237693 2026-002
    Material Weakness Repeat
  • 1237694 2026-003
    Material Weakness Repeat
  • 1237696 2026-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $20.08M
84.063 FEDERAL PELL GRANT PROGRAM $6.97M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $228,254
84.033 FEDERAL WORK-STUDY PROGRAM $216,846
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $179,835
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $137,678