Finding Text
Reporting of disbursement dates to the Common Origination and Disbursement system
Type of Finding - Significant deficiency in internal control over compliance
Program: Student Financial Assistance Cluster
Assistance Listing Number: Federal Pell Grants 84.063, Federal Direct Loans 84.268
Federal Agency: U.S. Department of Education
Criteria - 34 CFR 690.83 states that institutions are required to submit accurate direct loan, Pell grant, and TEACH grant disbursement records to the Common Origination and Disbursement system (COD).
Condition - Two students were found to have a disbursement date submitted to the COD system that was inconsistent with the disbursement date within the College’s records. One student’s disbursement date had a four day difference and another student’s disbursement date had a twelve day difference between the College’s records and the date submitted to the COD.
Cause - A significant deficiency in internal control over compliance exists relating to reporting of information to the COD. The College’s financial assistance software pulled the incorrect date for each of the identified students’ disbursements. This caused the incorrect date to be submitted to the COD. The internal controls to ensure accuracy and completeness was not effective at preventing or detecting and correcting these inconsistencies.
Effect - The disbursement dates were reported incorrectly and not corrected timely in the COD system.
Questioned Costs - Not Applicable.
Context - Two students out of a sample of forty were found to have the incorrect dates submitted to the COD system.
Identification as a Repeat Finding - Not Applicable.
Recommendation - We recommend the individual responsible for reconciling the information submitted to the COD system receive training on the requirements and the review of the dates being submitted be performed as a level of precision to detect and correct inconsistent reporting of disbursement information.
Views of Responsible Official - Management concurs with the finding and is providing those responsible for compliance with education on the compliance requirements. The College is reviewing the processes and controls and will make changes as necessary to prevent and/or detect and correct noncompliance on a timely basis.