Finding Text
Criteria or specific requirement: The U.S. Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not report Direct Loan disbursements within the required 15 days. Questioned Costs: None Context: During our testing, we noted two Direct Loan disbursements of the 40 Pell and Direct Loan disbursements tested were not reported to COD within the required 15 days. The two disbursements were for the same student. Cause: The student's master promissory note had expired by the time the student's third disbursement for fiscal year 2022 was made. Because of this, the College?s software would not report the disbursement date to COD. The College manually applied the disbursement date in COD. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes. Prior year finding number was 2021-003. Recommendation: We recommend the College evaluate the limitations of their software around COD reporting and establish procedures and policies that address any limitations around reporting disbursements to COD to ensure that student information is reported timely. Views of responsible officials: There is no disagreement with the audit finding.