Finding Text
Audit Finding Reference Number
2023 - 003 - Common Origination and Disbursement (COD) System
Federal Program and Specific Federal Award Identification
CFDA Title and Number
84.063 Federal Pell Grant Program (PELL)
84.268 Federal Direct Student Loan (Direct)
Federal Award Year
June 30, 2023
Federal Agencies
U. S. Department of Education
Pass-Through Entity
Not applicable
Criteria
OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (1) Financial Reporting, indicates that schools submit PELL origination records and disbursement records to the COD system. Key items on the origination records are social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. Institutions must report student payment data within 30 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data.
Conditions and Contexts
I noted the following conditions during my testing of the COD system:
• The PELL amount was disbursed in the COD system did not agree to the students’ billing statements for four (4) students out of eighty-eight (88). The billing statements under reported $1.587;
• The Direct loan amounts disbursed in the COD system did not agree to the students’ billing statements for three (3) students out of seventy-one (71) tested. The billing statements under reported $3,316; and
• The enrollment date was incorrectly reported in COD for seventy-five (75) students out of ninety-three (93) tested.
Cause
ABC failed to adhere to established procedures in reporting to the COD system.
Questioned Costs
For purposes of this condition, I have no questioned costs.
Effect
ABC has not complied with Title IV regulations that require proper and accurate recording to the COD system.
Repeat Finding
Yes. See Schedule of Prior Year Audit Finding 2022-003.
Recommendation
I recommend that ABC implements controls to ensure that information reported to the COD system is accurate.
Management's Response
Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to managing the COD system.
Responsible Administrators: Director of Financial Aid & Chief Financial Officer
Effective: Immediately and ongoing