Finding Text
Criteria: In accordance with the Student Financial assistance cluster from the 2024 compliance supplement, "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: We reviewed a sample of 40 students who received financial aid. Out of the 40 students tested, 23 students cost of attendance per the student records did not agree to the amounts reflected in COD originations records.
Effect: Incorrect or late reporting to the Common Origination and Disbursement (COD) System can lead to serious consequences for both institutions of higher education and their students. For institutions, delays in reporting may hinder access to federal funds, disrupt cash flow, and delay financial aid disbursements to students. Persistent errors can increase administrative burdens, require extensive corrections, and may lead to heightened scrutiny, such as being placed on Heightened Cash Monitoring (HCM) by the U.S. Department of Education (ED). Compliance failures can also damage an institution's reputation among prospective students and stakeholders. For students, these issues can result in delayed receipt of financial aid, insufficient or excessive funding, and complications with loan repayment, servicing, or eligibility for loan forgiveness. Timely and accurate reporting is critical to avoid these challenges and ensure smooth operations and compliance with federal regulations.
Cause: The District relied upon data exported from EDExpress to be accurately imported to COD. An error in the software caused inconsistent data to be pulled into the required fields, and the imports were not reviewed in detail.
Recommendation: We recommend that COD information is reviewed by an individual independent of the reporting process to verify that the amounts reported are accurate with the source data.