2023-006: 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, 2022 – June 30, 2023
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: During audit procedures, we noted the following items were incorrectly reported to the COD:
Fall 2022
• For 1 of 10 students tested, the Unsubsidized Direct Loan disbursement dates did not match between COD and the student ledgers.
• For 1 of 5 students tested, the Parent Plus Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date
Spring 2023
• For 2 of 10 students tested, the PELL applied dates did not fall within the 15 day requirement from the disbursement date.
• For 2 of 12 students tested, the Subsidized Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date.
• For 1 of 10 students tested, the Unsubsidized Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date.
• For 2 of 5 students tested, the Parent Plus Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date.
Summer 2023
• For 5 of 10 students tested, the PELL disbursement dates did not match between COD and the student ledgers.
• For 3 of 12 students tested, the Subsidized Direct Loan disbursement dates did not match between COD and the student ledgers.
• For 2 of 10 students tested, the Unsubsidized Direct Loan disbursement dates did not match between COD and the student ledgers.
• For 2 of 5 students tested, the Parent Plus Loan disbursement dates did not match between COD and the student ledgers.
• For 1 of 10 students tested, the Unsubsidized Direct Loan applied dates did not fall within the 15 day requirement from the disbursement date.
Questioned Costs: None.
Context: During audit procedures, we noted the following items:
Fall 2022
• The Unsubsidized Direct Loan disbursement date in COD for the student in question is 09/06/2022, but on the student ledgers the date is 09/21/2021.
• The Parent Plus Direct Loan Fall 2022 applied date in COD for the student in question is 6/28/2023, and the disbursement date in COD is 12/5/2022, which is 141 business days.
Spring 2023
• The Pell applied dates in COD for the students in question are 04/03/2023, and the disbursement dates in COD are 02/21/2023, which is 30 business days.
• The Subsidized Direct Loan applied date in COD for one student in question is 03/10/2023, and the disbursement date in COD is 01/27/23, which is 30 business days. The Subsidized Direct Loan applied date in COD for the other student in question is 02/21/23, and the disbursement date in COD is 01/27/2023, which is 17 business days.
• The Unsubsidized Direct Loan applied date in COD for the student in question is 08/18/2023, and the disbursement date in COD is 01/27/2023, which is 141 business days.
• The Parent Plus Direct Loan applied date in COD is 05/08/2023 for the student in question, and the disbursement date in COD is 03/31/2023, which is 26 business days.
Summer 2023
• The Pell disbursement dates in COD for the students in question are 06/16/2023, but on the student ledgers the dates are 06/20/2023.
• The Subsidized Direct Loan dates in COD for the students in question are 06/16/2023, but on the student ledgers the dates are 06/20/2023.
• The Unsubsidized Direct Loan disbursement dates in COD for the students in question is 09/06/2022, but on the student ledgers the date is 09/21/2021.
• The Parent Plus Direct Loan disbursement dates in COD for the students in question are 06/16/2023, but on the student ledgers the dates are 06/20/2023.
• The Unsubsidized Direct Loan applied date in COD for the student in question is 08/18/2023, and the disbursement date in COD is 06/20/2023, which is 43 business days.
Cause: Employee turnover during the 2022-2023 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: Yes – 2022-007.
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.