Finding Text
Audit Finding Reference Number
2022 - 003 - Common Origination and Disbursement (COD) System
Federal Program and Specific Federal Award Identification
CFDA Title and Number
84.063 Federal Pell Grant Program (PELL)
84.268 Federal Direct Student Loan (Direct)
Federal Award Year
June 30, 2022
Federal Agencies
U. S. Department of Education
Pass-Through Entity
Not applicable
Criteria
OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (1) Financial Reporting, indicates that schools submit PELL origination records and disbursement records to the COD system. Key items on the origination records are social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. Institutions must report student payment data within 30 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data.
Conditions and Contexts
I noted the following conditions during my testing of the COD system:
• The PELL amount was disbursed in the COD system did not agree to the students’ billing statements for twenty-one (21) students out of sixty-three (63). The billing statements reported an excess of $36,383;
• The Direct loan amounts disbursed in the COD system did not agree to the students’ billing statements for twenty-nine (29) students out of seventy-one (71) tested. The billing statements reported a decrease in Direct loans of $1,437; and
• The enrollment date was incorrectly reported in COD for ten (10) students out of sixty-three (63) tested.
Cause
ABC failed to adhere to established procedures in reporting to the COD system.
Questioned Costs
For purposes of this condition, I have no questioned costs.
Effect
ABC has not complied with Title IV regulations that require proper and accurate recording of the COD system.
Repeat Finding
Yes. See Schedule of Prior Year Audit Finding 2021-003.
Recommendation
I recommend that ABC implements controls to ensure that information reported to the COD system is accurate.