Finding Text
2022-007: Reporting – Common Origination and Disbursement (COD)
Federal Agency:
Department of Education
Federal Program Title:
Student Financial Aid Cluster
Assistance Listing Number:
84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A215801 (March 25, 2021 - August 31, 2027),
P033A215801(July 1, 2021 - August 31, 2027),
P063P213807(March 23, 2021 - August 31, 2027),
P268K223807(January 1, 2021 - July 31, 2043)
Award Period:
July 1, 2021 – June 30, 2022
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a 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 statutes, 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). Compliance- From the 2022-23 FSA Handbook: to be in compliance with reporting disbursements and disbursement adjustments within 15 days. The date funds are credited to a student’s account in the institution’s general ledger or any subledger of the general ledger or paid to a student directly is the disbursement date the financial aid office reports to COD. The Common Origination and Disbursement (COD) additional requirements are:
(1) Schools must use the COD system to request and receive federal student aid funds, including Direct Loans, Pell Grants, and Campus-Based aid programs. Schools must ensure that all disbursements of federal student aid are made through the COD system.
(2) Schools must reconcile their records with the COD system to ensure that all disbursements are accurately reported and recorded.
(3) Schools must comply with COD reporting requirements, including reporting disbursements, adjustments, and cancellations in a timely and accurate manner.
Condition: For one (1) of 33 students tested, the Fall 2022 disbursement dates in COD for Pell did not match the disbursement date on the student ledgers.
Questioned Costs: None.
Context: The Fall 2022 disbursement dates in COD for the student in question is October 29, 2021, but on the student ledger the date is December 15, 2021.
Cause: Employee turnover during the 2021-2022 academic year caused this process to not be completed accurately.
Effect: The University is not complying with federal requirements of reporting and information-sharing requirements established by the Department of Education.
Repeat Finding: No
Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.