Finding Text
Reporting - Direct Loan and Pell Common Origination and Disbursement (“COD”) Compliance and
Internal Control (Significant Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Direct Student Loans (Federal Assistance Listing #84.268) Federal Award Number: P268K231804
Federal Pell Grant Program (Federal Assistance Listing #84.063) Federal Award Number: P063P221804
Federal Award Year: 2022-2023
Criteria and Context:
Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant and 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. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution: (a) credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department of Education.
Condition and Sample Method:
From a non-statistical sample of forty (40) students selected for COD reporting testing, we identified one (1) student whose Direct Loans or Pell disbursement record was submitted to the COD more than 15 days after the award was disbursed to the student.
Cause and Effect:
While the College had certain procedures in place to monitor the submission of the disbursement records, such procedures were not consistently performed on a timely basis, and therefore were not adequate to ensure that each record was submitted within the required timeframe, causing the late submission of certain disbursement records.
Questioned Costs:
None identified.
Identified as a Repeat Finding:
No.
Recommendation:
We recommend that the College strengthen its policies and procedures to ensure that student disbursement records are submitted accurately to the COD within 15 days of disbursements being made to students’ accounts, and that the College maintain clear evidence that a secondary review is performed to verify that the submission was made timely.