Finding Text
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The dates when Federal Direct Loans (FDL) and Pell were disbursed to student's account did not always agree to the disbursement dates as reported in COD.
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 259 subsidized, unsubsidized, Plus loans, and Pell disbursement records tested, 25 had COD loan and Pell disbursement date errors. The errors were primarily a spring 2023 disbursement batch which reported Pell and FDL disbursements to COD as 2/21/2023 but were actually posted to the students’ accounts on 3/24/2023. There were no errors in the amounts reported, just the date of disbursement and the funds were not drawn down from G5 until 3/28/2023 so no cash management violation noted.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students' accounts.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.