Finding Text
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The FDL amounts posted to student account did not always agree to disbursement records reported to Common Origination and Disbursement (COD) for one student.
Criteria: 34 CFR 668.164(a)
Questioned Costs: $-0-
Context: One of 51 students tested, 1 student had a COD loan disbursement amount error of approximately $1,000 that was not caught in the monthly reconciliation.
Cause: There was a miscommunication between the third party administrator and the College, and the monthly reconciliation process did not identify the discrepancy.
Effect: Inaccurate FDL reporting can impact a student’s interest accumulating period based on the dates and amounts of the loan disbursement dates as well as the monitoring of FDL aggregate limits for subsidized and unsubsidized loans.
Identification as repeat finding, if applicable: Yes, see 2022-003.
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and amounts and that all dates and amounts be part of the monthly reconciliation process.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.