Finding Text
Criteria or Specific Requirements
Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data.
Condition
Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit.
Cause
The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting.
Effect
The District is not in compliance with the aforementioned criteria.
Context
During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students.
Questioned Costs
There are no questioned costs associated with this finding.
Repeat Finding (Yes or No)
No.
Recommendation
The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.