Finding Text
Finding 2023-003– Common Origination and Disbursement (COD) Reporting
Repeat Finding: No
Federal Program Title – U.S. Department of Education
Student Financial Assistance Cluster
Federal Direct Student Loans: 84.268
Federal Pell Grant Program: 84.063
Federal Award Year 2022-2023
Condition
For ten out of forty students tested (25%), the College did not report certain disbursements of financial aid to COD within the require fifteen days from the date of disbursement. In all instances, the disbursements were reported one day late.
Criteria
For the Direct Loan and Pell Grant Programs, Institutions must report student disbursement data to COD 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.
2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure timeliness of transmission of disbursement records to COD.
Questioned Costs
There were no questioned costs with respect to this finding.
Cause
The financial aid office inadvertently miscalculated the reporting date.
Prevalence
Frequent. Ten out of forty students selected for testing.
Effect
Failure to report disbursement records to COD could result in loss of future funding.
Recommendation
We recommend City Colleges enhance their policies and procedures to ensure COD disbursement records are transmitted to COD within the required timeframe.
Views of responsible officials
We agree with this finding. See corrective action plan.