Finding Text
Finding number: 2023-001
Federal agency: U.S. Department of Education
Programs: Federal Direct Student Loans
AL #’s: 84.268
Award year: 2023
Criteria
According to 34 CFR 690.83(b):
(1) An institution shall report to the Secretary any change for which a student qualifies
including any related Payment Data changes by submitting to the Secretary the student’s
Payment Data that discloses the basis and result of the change in award for each student.
The institution shall submit the student’s Payment Data reporting to the Secretary by the
reporting deadlines published by the Secretary in the Federal Register.
(2) An institution shall submit, in accordance with the deadline dates established by the
Secretary, through publication in the Federal Register, other reports and information the
Secretary requires and shall comply with the procedures the Secretary finds necessary to
ensure that the reports are correct.
According to the Federal Register (Volume 83, Number 233):
An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan,
and TEACH Grant disbursement records to COD, 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, Higher Education Act (“HEA”) 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, HEA program funds are disbursed even if an institution uses its own funds in
advance of receiving program funds from the Department.Condition
Federal regulations require the Academy to report Direct Student Loan disbursements made to
students to the Federal Government’s Common Origination and Disbursement System (“COD”)
within 15 days of the funds being disbursed to the student. During our testing, we noted 1 student,
out of a sample of 32 Direct Student Loan recipients, were not reported within the required
timeframe.
Cause
The Academy has policies and procedures in place to report the disbursement records to the
Department of Education through the COD system within the required fifteen calendar days;
however, in this case the procedures were not completed properly.
Effect
The Academy did not report Direct Student Loan disbursements to COD within the required time
frame.
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 32 students selected for
testing, 1 student, or 3% of our sample, was determined to be reported late to the COD.
Identification as a Repeat Finding, if applicable
See finding 2022-001 included in the summary schedule of prior year findings.
Recommendation
We recommend that management of the Academy review, and if necessary, update the policies
and procedures to ensure all Direct Student Loan funds are reported within the required timeframe.
View of Responsible Officials
The Academy agrees with the finding.