COD Reporting Errors
Audit Finding:
Two students had incorrect disbursement information reported.
Out of a population of 6,385 students with disbursements during the Spring and Fall semesters of the 2024 aid year, 25 were selected for testing. Of those students, two had the incorrect disbursement date reported. Our sample was not, and was not intended to be, statistically valid.
Cause of the Finding:
The University did not have appropriate controls in place to ensure accurate reporting.
Effect of the Finding:
The University reported inaccurate information and, as such, ED was not provided accurate information.
Acknowledgement of the Finding:
We acknowledge the audit finding regarding the discrepancies between the disbursement dates reported to the Common Origination and Disbursement (COD) system and the actual disbursement dates. We understand the importance of aligning these dates to ensure accurate federal reporting and compliance with Title IV regulations.
Risk Acceptance:
After careful consideration, we have determined that we are willing to accept the risk associated with the mismatches in COD disbursement dates. We believe that the discrepancies identified have not resulted in significant adverse impacts on our federal aid programs or student aid disbursement processing. Furthermore, we assess that the likelihood of material financial or operational consequences arising from these discrepancies is low.
Rationale for Accepting the Risk:
o The mismatched disbursement dates were not caused by fraudulent activity or intentional misreporting.
o There is no evidence of overpayments or underpayments of Pell Grant funds to students as a result of the discrepancies.
o The institution has a long history of successfully managing federal aid programs, and the current system's checks and balances are deemed adequate to ensure that aid is disbursed correctly, even if the dates reported to COD do not exactly match the dates the funds were disbursed.
o The impact on reconciliation and compliance has been minimal, and we have not encountered significant issues in our annual reviews with the Department of Education.
o The mismatches are not expected to have any significant impact on our ability to meet Title IV reconciliation deadlines or other reporting requirements.
Mitigating Actions:
While we are willing to accept the risk associated with these mismatches, we will continue to take steps to mitigate any potential negative impacts and improve our internal processes, including:
o Monitoring and Review: We will conduct periodic reviews to identify any significant discrepancies and address them promptly. Any material issues that arise in the future will be corrected as needed.
o Reconciliation Process: We will continue to ensure that our reconciliation process between our internal system and COD is robust, even if mismatched dates are accepted. Any discrepancies will be reviewed at regular intervals to verify accuracy.
o Training: We will provide ongoing training to staff responsible for Pell Grant disbursements and reporting to COD to ensure they are aware of the risks and potential consequences of incorrect disbursement date reporting.
o Documentation of Decisions: We will maintain documentation of the decision to accept the risk and will revisit this decision as part of our annual risk assessment to ensure that it continues to align with institutional goals and compliance objectives.
Conclusion:
We are confident that the risk of COD disbursement date mismatches will not significantly impact our overall compliance or federal aid management. However, we remain committed to continuous monitoring and improvements in our processes to ensure accurate reporting and minimize any potential future issues.
Responsible Parties:
The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Senior Director Student Financial Services and Operations.
Responsible party contact information is located at uco.edu.