Finding Text
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. 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: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: 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. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.