Finding Text
Criteria:
Pursuant to Federal Register Volume 85, Number 134, an institution must submit Direct Loan disbursement records to the Common Origination and Disbursement (“COD”) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. As defined in 34 CFR 668.164(a), the disbursement date is the date that a school credits a student’s account at the school or pays a student or parent borrower directly with Title IV funds received from the U.S. Department of Education or with institutional funds in advance of receiving Title IV program funds.
Condition and Context:
From a selection of forty (40) Direct Loan disbursements tested, we identified seven (7) disbursements involving three (3) students, that were reported to the COD system more than 15 days after the respective disbursement dates.
Cause:
The College maintained list creation rules to create lists of students with federal grants. The College discovered that the rules failed to pull students registered for at least six (6) credits when creating the lists.
Effect:
Two hundred and five (205) Direct Loan disbursements were not identified and submitted in the September 15, 2022 submission. Once the error was uncovered, the students were reported on the October 6, 2022 submission. Accordingly, the students were not reported to the COD system within the 15 day timeframe stipulated in Federal Register Volume 85, Number 134.
Questioned Costs:
None noted.
Identified as a Repeat Finding:
A similar finding was not reported in 2022.
Recommendation:
The College should review the effectiveness of its procedures governing the timely submission of Direct Loan disbursements to the COD system to ensure such records are submitted within the appropriate timeframe.