Finding Text
2023–002 Common Origination and Disbursement (COD) Reporting
Federal Agency: Department of Education
Federal Program: Student Financial Aid Cluster
CFDA Numbers: 84.268 – Federal Direct Loan Program, 84.063 Pell Grant Program
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Other Matter
Criteria or specific requirement:
The Department of Education requires institutions to report disbursement dates and amounts to the
COD system (34 CFR 690.83(b)(2) for Pell and 34 CFR 685.301(c) for Direct Loans).
Condition:
For 17 of the 40 awards tested, the disbursement dates reported to COD were one day later than the
date the award was recorded in the student’s account.
Questioned costs:
None.
Context:
4 of the 17 awards were Pell awards and 13 were Direct Loan awards.
Cause:
The College’s policies and procedures did not ensure that all disbursement dates were reported accurately.
Effect:
The disbursement dates reported to COD were not accurate.
Repeat finding:
No.
Recommendation:
We recommend that the College review their reporting policies and procedures to ensure accurate reporting.
Views of responsible officials and planned corrective actions:
See Corrective Action Pan prepared by the College.