Finding Text
Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Award Period: September 1, 2021 through August 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Department of Education requires the University 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. Condition: During our testing, we noted that one Pell and five Direct Loan disbursements, of the 40 disbursements tested, had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None. Context: The student ledger reflected the posted date rather disbursement date from the financial aid system. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: Please refer to the attached corrective action plan.