Finding Text
Federal Program Information: Federal Pell Grant Program (ALN: 84.063) and Federal Direct
Loan Program (ALN: 84.268)
Criteria or Specific Requirement
(Including Statutory, Regulatory or
Other Citation):
L. Reporting – Financial Reporting – Federal regulations
require the University to submit origination and disbursement
records for students to the Common Origination and
Disbursement (“COD”) system. Items considered key in
student origination records, if applicable, are: Social Security
number, award amount, enrollment date, verification status
code (when the applicate is selected for verification),
transaction number, COA, and the “Academic Start Date” and
“Academic End Date”. Institutions must also submit
disbursement records to the COD for students no earlier than
7 calendar days prior to the disbursement date, and no later
than 15 calendar days after the institution makes a
disbursement.
Condition: For certain students identified through our testing, errors
were identified in key items reported to the COD in student
origination records. Additionally, the University failed to
report disbursement records for certain students within the
required timeframe.
Cause: Administrative oversight with respect to accurate reporting
of federal award information.
Effect or Potential Effect: The University was not in compliance with COD reporting
requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
For 5 of 25 students selected for origination record
testing, the student’s COA was inaccurately reported
within the COD system.
For 1 of 25 students selected for origination record
testing, the “Academic Start Date” was inaccurately
reported.
For 2 of 25 students selected for disbursement record
testing, the University waited more than 15 days after
making a disbursement of funds to report the required
disbursement information.
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University enhance its procedures to
ensure origination and disbursement records are reported
accurately and timely to the COD for Federal Direct Loan
Program and Federal Pell Grant Program recipients, in
accordance with federal regulations.
Views of Responsible Officials and
Planned Corrective Actions:
The University will transition from a manual to an automated
review process. The COA data that was inputted at the
beginning of the award year did not match all budget
components causing inaccuracies. The Financial Aid office
was adjusting the budget components of the COA manually,
which resulted in miscalculations. When these calculations
were performed COD might not have been updated and
therefore the COA could be inaccurately reported. During the
2023 and 2024 fiscal years the Financial Aid office
experienced several staffing changes. The Financial Aid office
will review all student COA calculations to ensure that the
COA used for originating and disbursing funds is correct. The
Financial Aid office will set up automatic processing of key
reports to identify rejected origination records. The Financial
Aid office will set up the Direct Loan COD Reject Report
(DCRR) and the Pell COD Reject Report (PCRR) to run Sunday
night and be available Monday morning to be reviewed by the
Financial Aid Advisors. The Financial Aid office will make the
necessary corrections and update by the end of the week. The
Financial Aid office will run Batch FA Transmittal Register
(FATR) to confirm that all anticipated awards have passed all
rules and are ready to transmit. Those that don’t pass will be
reviewed and students will be contacted for
updated/corrected information. COD records will be
exported nightly through an automated process to ensure all
deadlines are met and that we are not exceeding the 15
calendar day limit.
The Financial Aid office has also modified the setup of their
Student Information System for 2024-2025 so that the COA
will be automatically calculated which will eliminate the
need for any manual calculations of COA. This automated
process should eliminate improperly calculated COAs.