Finding Text
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting.
Questioned costs: None reported.
Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred.
Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available.
Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.