Finding Text
Direct Program - Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268
Award Numbers: Not Available
Compliance Requirement: Reporting – Common Origination and Disbursement (COD) System Type of Finding: Significant Deficiency in Internal control over Compliance
Criteria: Institutions must report student disbursement data within 15 calendar days to the COD system 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 (34 CFR 690.83).
Condition: In our testing of 60 samples, 1 student was not reported to the COD system within 15 days of disbursement.
Cause: A student’s FASFA was updated prior to the scheduled disbursement of a Pell grant award resulting in a hold on the student’s account so the District could review the update. This initial disbursement date was reported to the COD system although the disbursement did not occur. The disbursement was subsequently made but the date of disbursement was not updated and it was not updated within 15 days of the actual disbursement.
Effect: Disbursement information was not reported to COD system within 15 days of disbursement or adjustment.
Questioned Costs: None reported
Context/Sampling: Nonstatistical sample of 60 students receiving financial aid out of 2,372 total students receiving financial aid.
Repeat Finding from Prior Year: No
Recommendation: The District should have a compensating control or process to ensure timely reporting of disbursements and changes in disbursements to the COD system.
Views of Responsible Officials: The District’s management agrees with the finding.