Finding Text
2023-007 – Reporting – Material Weakness in Internal Controls
Student Financial Assistance Cluster
U.S Department of Education
Federal Assistance Listing Number: 84.063, 84.268
Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans
97
Criteria: OMB Compliance Supplement, OMB No. 1845-0039 – Institutions are required to submit Direct Loan,
Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination
and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the
disbursement. Institutions must report student disbursement data within 15 calendar days after the institution
makes a disbursement or becomes aware of the need to make an adjustment to previously reported student
disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15
calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a
timely manner.
Condition/context: During our testing we noted 82 out of 100 disbursement transactions tested where the
disbursement date per the students records and the disbursement date per COD did not agree. We noted in 2 out
of 100 transactions, the amount per the student record and amount per COD did not agree.
Questioned costs: None.
Cause/Effect: The College did not have adequate and/or functioning controls in place to ensure the reporting of
disbursements to students on COD was submitted timely and that the dates and amounts agreed. The
administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement
information reported by institutions. The College is not in compliance with the federal COD reporting requirements
described in the OMB Compliance Supplement and required by the Department of Education.
Repeat finding: Yes, 2022-004
Recommendation: The College should implement a process to review, update, and verify student disbursements
are reported to COD accurately and timely.
Views of responsible officials and planned corrective actions:
Responsible Individuals: Michael N. Espinoza, Vice President of Student Services
Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent
reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has
entered into an agreement with a third-party financial aid provider to service and administer financial aid awards,
COD reporting and reconciliation.
The College will implement a process to review, update, and verify student disbursements are reported to
COD accurately and timely.
Prevention to include creation of reports for awards pending and detailed disbursement and
reconciliations schedules, and system back-end processes.
Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure
distribution in compliance with Common Origination and Disbursement (COD).
Anticipated Completion Date: to be completed by June 30, 2024