Finding Text
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns
acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. 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: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days.
For 3 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD.
Views of Responsible Officials: The University has implemented a weekly COD maintenance file update that will report any change activity to a student’s COD funds. This process is ensured to take place by on-going calendar reminders as well as progress checks between the Director and Assistant Director.