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FINDING 2026-003 Federal Program Information: Federal Pell Grant Program (Assistance Listing #84.063) Criteria or Specific Requirement: L. Reporting – Financial Reporting – Federal regulations (34 CFR 668.164(b)(3)(iii)) require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: Certain origination records contained inaccurate data. Cause: Administrative oversight and insufficient internal control. Effect or Possible Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: For 2 of 25 origination records tested, the University did not accurately report all key items. Identification of Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure accurate reporting of origination data. Views of Responsible Officials: Upon review of the data that was reported inaccurately, it was determined that updating this data point, the earliest enrollment date for the award year, via a systems integration was not the most reliable way to update the value. An internal system within the Financial Aid Management System (FAMS) will be used to populate this date going forward. The Financial Aid Office will add an additional quality check post origination as well to ensure accuracy.