Finding Text
Criteria or specific requirement: The Department of Education requires institutions 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. The
Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal
controls which provide reasonable assurance that federal award expenditures are in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal Award.
Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15
days to COD.
Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement
dates.
Questioned costs: N/A
Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements
are reported within 15 days to COD.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation
could be misstated due to the discrepancy in disbursement dates reported.
Repeat finding: No
Recommendation: We recommend that the student financial aid department work to ensure
disbursements are reported to COD within 15 days of the disbursement date.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.