Finding Text
2023–003: Common Origination and Disbursement (COD) Reporting
Federal agency: U.S. Department of Education
Federal program title: Student Financial Aid Cluster
Assistance Listing Numbers: 84.268, 84.063
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:
The Department of Education requires the College to report the disbursement dates and amounts to the COD system within 15 days of disbursing Pell (34 CFR 690.83(b)(2)) and Direct Loan (34 CFR 685.309) funds to a student.
Condition:
During our testing of 40 disbursements, we noted 4 disbursements that were not reported to COD in a timely manner.
Questioned costs:
None.
Context:
Disbursements were not reported to COD within the required 15 days.
Cause:
Due to turnover, management did not ensure disbursements were reported to COD within prescribed timeframes.
Effect:
The College is not in compliance with the Department of Education regulations.
Repeat Finding:
No
Recommendation:
We recommend the College evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely.
Views of responsible officials:
There is no disagreement with the finding.