Finding Text
2023 – 001: Common Origination and Disbursement
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.063
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
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.
Condition: CLA 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: None
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: CLA recommends that the student financial aid department review and revise processes and controls related to disbursements are reported to COD within 15 days of the disbursement date.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.