Finding Text
Common Origination and Disbursement (COD) Reporting Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Federal Pell Grants (Pell) and Federal Direct Loans (FDL) to COD. Additionally two students did not have aid posted on their student accounts but it was reported to COD as disbursed.
Criteria: 34CFR 668.164(a)
Questioned Costs: $5,938
Context: 24 of the 55 tested had COD FDL disbursement date errors ranging from 24-25 days for a disbursement batch in March 2023. 1 of the 32 Pell students tested had a COD disbursement date error that was 108 days. 2 of the 55 tested had FDL disbursement amounts reported to COD incorrectly for disbursements not made on the student account. This resulted in incorrectly reporting $3,217 and $2,721 of Federal Direct Loan disbursements for each student, respectively. The University disbursed these amounts on the student accounts at a later date during the audit.
Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students’ accounts. Reconciliations of University records to COD were not completed regularly so the discrepancies between the two systems were not identified and corrected in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates as well as the monitoring of FDL aggregate limits. 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.