Finding Text
2023-005: Reporting: Common Origination and Disbursement
Federal agency: U.S. Department of Education
Federal program title: Student Financial Assistance
ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Department of Education requires institutions 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.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During testing of Common Origination and Disbursement reporting, we noted 4 instance of noncompliance.
Questioned costs: None.
Context: During our testing of 40 COD disbursements we identified, 3 disbursements were not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student.
Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No.
Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student.
Views of responsible officials: There is no disagreement with the audit finding.