Finding Text
Criteria
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. The disbursement record reports the actual
disbursement date, amount of the disbursement, enrollment dates, and the cost of attendance. 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.
Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must
establish and maintain effective internal control over the Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). Condition
In testing the origination and disbursement data, key items to test on origination records, if applicable, are:
Social Security number, award amount, enrollment date, verification status code, transaction number, cost
of attendance, and academic calendar.
During our testwork over the key items on origination records as reported on COD, KPMG identified the
following:
• 15 of the 40 students selected for testwork had cost of attendance amounts that did not agree to the
College’s records.
• 6 of the 40 students selected for testwork had academic start or end dates that did not agree to the
College’s records.
None of the items that were exceptions described above resulted in changes to the amounts awarded or
disbursed to students by the College for the current fiscal year.
Cause
The condition resulted from the College Student Financial Aid Operations Department not reporting
updated information to the COD System when changes were made to enrollment dates or the cost of
attendance of the students identified due to the College not having an adequate internal control process.
Possible Asserted Effect
Failure to provide required key item information in accordance with federal requirements and implement
sufficient internal controls to ensure the programs are operating effectively could have resulted in the
College awarding or disbursing incorrect amounts to students.
Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend the College review and enhance its process related to reporting key items to the COD
System and update key fields as information may change during the awarding process to ensure that they
agree to the College’s records.