Finding Text
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.268 – Federal Direct Student Loans
Federal Award Identification Number and Year: P268K220355 - 2023
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter
Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing of the submission of disbursement records to COD, we noted the disbursement dates on COD were different than the disbursement date per the College’s records.
Questioned Costs: None
Context: During our testing of the submission of disbursements records to COD, we noted the disbursement date for 7 of 29 direct loan disbursements tested were different by one day between COD and the College’s records.
Cause: The College reported the disbursement date to COD and the disbursements were not posted to student accounts until the next day.
Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards.
Repeat Finding: Yes. Prior year finding 2022-003
Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported timely.
Views of responsible officials: There is no disagreement with the audit finding.