Finding Text
2023–005 Common Origination and Disbursement (COD) reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
CFDA Number: 84.268 – Federal Direct Student Loans, 84.063 – Pell Grant Program
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: As defined in 34 CFR 668.164(a), the disbursement date is the date that a school credits a student’s account at the school or pays a student or parent borrower directly with Title IV funds received from the U.S. Department of Education (the Department) or with institutional funds in advance of receiving Title IV program funds. This is the date that a school must report to the COD System as the actual disbursement date for a Direct Loan, as distinguished from the anticipated disbursement date.
Condition: During our testing we noted instances where the wrong disbursement date was reported to COD.
Questioned costs: None
Context: Of the 148 disbursements tested, we noted 9 instances where the wrong disbursement date was reported.
Cause: University’s policies and procedures did not ensure compliance.
Effect: Noncompliance with the reporting requirements.
Repeat Finding: No.
Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting.
Views of responsible officials: See Corrective Action Plan prepared by the University.