Finding Text
Federal Program Information: Direct Student Loans Program (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: One student disbursement was not reported to COD within 15 calendar days as required.
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 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendars days.
Identification as a Repeat Finding: This is a repeat of Finding 2023-001.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD.
Views of Responsible Officials: As a result of Audit Finding 2023-001 the University had implemented a weekly COD Maintenance Files for Direct Loans and Pell Grants. The 2024-001 Finding is a result of an oversight in the setup of the one student record that caused the information to not be picked up and included in the weekly file. The problem has now been identified and corrected to ensure that such an oversight does not reoccur. Additionally, the University has implemented a new policy in terms of creating and updating student records.