Finding Text
Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.