Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education's Common Origination and Disbursement (COD) which is a web-based system for processing, storing and reconciling DL financial aid data. Each month, the COD provides Institutions with a School Account Statement (SAS) date file which consists of a Cash Summary, Cash Detail and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the Insitution's financial records ("DL Reconciliations"). While the University has made significant improvements in this reconciliation process and that of the other related federal award programs, there are still unreconciled differences in all three major federal pass-through program's reonciliations as noted in the financial statement audit. However, for FY23, these differences netted to an immaterial difference overall and were no adjusted / passed during the financial statement audit. However, differences still remain, and the reconciliation process still needs to be improved upon. The University concurs with the audit finding and will adhere to the corrective action plan. Corrective action: The Student Financial Aid activity was reconciled among the Registrar, Financial Aid, and Business Offices as of June 30, 2023, at detailed (student) level. Monthly reconciliations will be maintained effective July 2023. Responsible Person(s): Robert Merino, Executive Director of Financial Aid jrmerino@vuu.edu 218 795-6190. Planned Date of Completion of Corrective Action: December 31, 2023.