Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 01, 2022 - June 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309).
Condition: During our testing of 40 students, we noted the following:
6 disbursement dates were incorrectly reported to the COD
3 disbursement amounts were incorrectly reported to the COD
10 disbursements were not reported to the COD in a timely manner
Questioned costs: None.
Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect dates or disbursement amounts.
Cause: The University had errors within their batch process reports used when reporting to COD.
Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported.
Repeat finding: No.
Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely.
Views of responsible officials: Management agrees with the finding.