Finding Text
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.