Finding Text
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. 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: Certain student disbursements were not reported to COD within 15 calendar days as required. Additionally, during an examination of Direct Loan disbursement records, an instance in which loan proceeds were disbursed prior to having obtained a legally enforceable promissory note was identified. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 1 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Direct Loan disbursement records tested, the University disbursed loan proceeds without having obtained a legally enforceable promissory note. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD. Views of Responsible Officials: A system error prevented scheduled Pell disbursements from taking place on the appropriate day thus creating a discrepancy in the timing of reporting. This discrepancy created the need for all disbursements to be verified manually and during the time needed to complete verification of the disbursement, the University was out of compliance. New reports have been created to ensure that all scheduled disbursements have disbursed within the University system and in the COD system and are accurately reported within the 15 calendar days as required. In the case of the identified student and their Direct Loan disbursement, the student?s Unsubsidized loan was inadvertently disbursed with required documents missing. The University has put in to place a series of reports and measures that ensures a loan will not disburse if a student is missing required documents or is not in one of Powerfaids ?Ready to Disburse? statuses.