Finding Text
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. 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 - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.