Finding Text
2022 ? 011: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P212439-2022, P268K222439-2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. 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. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: The University failed to comply with the reporting requirements of Common Origination and Disbursement (COD) in accordance with the stated criteria. Questioned costs: There are no questioned costs. Context: We noted eight (8) out of forty (40) students selected for testing, where there were discrepancies between the institutional records and the information included in COD. We noted four (4) exceptions where the disbursement date per the student account and the applied date at ED Per COD was greater than 15 days. We noted three (3) exceptions where the disbursement date per the student account did not agree to the disbursement date per COD. We noted one (1) exception where the amount per COD did not agree to the amount per the student account. Cause: The University?s internal controls failed to detect that the date being submitted to COD did not comply with the stated criteria. Effect: The University failed to comply with the stated criteria. Repeat Finding: No Recommendation: We recommend that the University update its processes and procedures related to reviewing the information submitted to COD to ensure compliance with the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.