Finding Text
Federal Program Information: Federal Direct Student Loan Program (ALN#: 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement (“COD”) System – All institutions receiving Direct Loans submit payment data to the Department of Education through the COD System. Institutions must report all loan disbursements and submit required records to the Direct Loan Servicing System (DLSS) via the COD no earlier than 7 days prior to making a disbursement of funds to a student (under the Advance or Heightened Cash monitoring 1 payment method), and no later than 15 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. (ED Notice, July 14, 2020, Federal Register (85 Federal Register 42368)).
Condition: Instance was identified where the student payments data was not submitted within the required timeframe.
Cause: Administrative oversight with respect to disbursement compliance requirements.
Effect or Potential Effect: The University was not in compliance with the Direct Loan reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 25 students selected for testing, the student payment data was not submitted within the required timeframe.
Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the University enhance its procedures to ensure Direct Loan payment data is submitted to the Department of Education within the required timeframe.
Views of Responsible Officials: The University Financial Aid Office has restructured the disbursement process as noted below:
• Staff members will be retrained on the importance of timely reporting and record compliance.
• A disbursement and documentation process will be created to track, manage, and reconcile the disbursement requests sent to COD. This process will aid in recognizing approved disbursements, rejected requests, and posting of disbursements.
• The disbursement and reconciliation log will be reviewed by the Asst. Vice President for Student Financial Services as well as the Asst Vice President for Analytics & Audit.