Finding Text
2023-002 Common Origination and Disbursement (COD)
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ALN Numbers: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Criteria or Specific Requirement: The Department of Education requires the University 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 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date.
Questioned costs: None
Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD.
Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date.
Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around reporting 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.