Finding Text
Criteria: Institutions must report all loan disbursements and submit required records to the Common
Origination and Disbursement System (COD) within 15 days of disbursement (OMB No. 1845-0021).
Direct Loan School Account Statement (SAS) reconciliations are a mandatory monthly process, as
required under 34 CFR 685.300(b)(5). A school should reconcile all cash (drawdowns and refunds of
cash) and disbursement records (actual disbursements and adjustments) with information in the Common
Origination and Disbursement (COD) System on an ongoing basis.
Condition/Context: For the period under audit, supporting evidence that SAS data files were reconciled
to the University’s financial records could not be provided.
Cause: The Universitys SAS data files and their reconciliation to internal financial records were not
properly documented and retained.
Effect: Lack of reconciliation procedures could result in improper data and within the COD system and
noncompliance in cash management of the direct loan program and/or noncompliance with disbursement
reporting requirements.
Questioned Costs: Not applicable
Recommendation: The University should put into place policies and procedures to ensure compliance
with federal grant reporting requirements, including documenting and retaining monthly SAS
reconciliations.
Management’s Response: Management understands the finding and will seek to add documentation
control procedures to ensure evidence of reconciliations are maintained.