Audit 27336

FY End
2022-06-30
Total Expended
$30.63M
Findings
24
Programs
9
Organization: Alverno College (WI)
Year: 2022 Accepted: 2023-03-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
20415 2022-001 Significant Deficiency - N
20416 2022-002 Significant Deficiency - N
20417 2022-001 Significant Deficiency - N
20418 2022-002 Significant Deficiency - N
20419 2022-001 Significant Deficiency - N
20420 2022-002 Significant Deficiency - N
20421 2022-001 Significant Deficiency - N
20422 2022-002 Significant Deficiency - N
20423 2022-001 Significant Deficiency - N
20424 2022-002 Significant Deficiency - N
20425 2022-001 Significant Deficiency - N
20426 2022-002 Significant Deficiency - N
596857 2022-001 Significant Deficiency - N
596858 2022-002 Significant Deficiency - N
596859 2022-001 Significant Deficiency - N
596860 2022-002 Significant Deficiency - N
596861 2022-001 Significant Deficiency - N
596862 2022-002 Significant Deficiency - N
596863 2022-001 Significant Deficiency - N
596864 2022-002 Significant Deficiency - N
596865 2022-001 Significant Deficiency - N
596866 2022-002 Significant Deficiency - N
596867 2022-001 Significant Deficiency - N
596868 2022-002 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $22.54M Yes 2
84.063 Federal Pell Grant Program $2.22M Yes 2
84.038 Federal Perkins Loan Program $732,657 Yes 2
84.033 Federal Work-Study Program $187,300 Yes 2
47.074 Biological Sciences $93,125 - 0
84.007 Federal Supplemental Educational Opportunity Grants $68,650 Yes 2
84.335 Child Care Access Means Parents in School $31,695 - 0
84.425 Education Stabilization Fund $5,992 Yes 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $1,868 Yes 2

Contacts

Name Title Type
WCMLW2MWGPZ4 Jean V. Norton Auditee
4143826188 Ryan Lay Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedules are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedules represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The College has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedules of expenditures of federal and state awards (the Schedules) includes federal and state award activity of Alverno College (the College) under programs of the federal and state governments for the year ended June 30, 2022. The information in these Schedules is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and the State Single Audit Guidelines. Because these Schedules presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net assets or cash flows of the College.
Title: Federal Student Loan Program Accounting Policies: Expenditures reported on the Schedules are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedules represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The College has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Federal Perkins Loan Program is administered directly by the College, and balances and transactions relating to this program are included in loans to students in the Colleges financial statements. Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the Schedules. The balance of loans outstanding at June 30, 2022 is $594,674. The Perkins Loan Program is ending and no additional loans are granted in the year ended June 30, 2022.

Finding Details

2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.
2022-001 Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management?s review of the federal aid refunds did not detect errors on certain refunds on Title IV grants. We identified the federal aid refunds for three (3) students were not calculated in a timely manner resulting in no amounts being refunded. Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV program as soon as possible, but no later than 45 days after the withdrawal date. Questioned Costs: The amount of known questioned costs was $18,292. The projected questioned costs is $73,500. Context: The College?s internal control over compliance did not detect that grant funds needed to be returned to Title IV. Of the 46 students who withdrew from the College and received Title IV grants, 18 students were tested and three (3) of the students tested received a refund that was required to be returned to the Title IV program. Cause: The College?s internal control over compliance did not detect the errors. Management has indicated the Return to Title IV (R2T4) calculation was not calculated correctly as the dates entered into the software were backdated due to the student officially withdrawing at a later date from last attendance. Effect: The College did not properly process the R2T4, therefore did not return the funds in a timely manner and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review their processes and controls in place to ensure appropriate refunds are made relating to Title IV grant funding in a timely manner. Management's Response: The College's Financial Aid department has adjusted how students are identified for a R2T4 calculation. Previously, we would work with a date range weekly. However, if there were status changes made that required changes to dates prior to the weekly reporting range, it would fall outside of our date range. Our new process is to use the first day of the semester as the start of our date range, as this will ensure that we catch all students that need a R2T4 calculation regardless of academic backdating.
2022-002 Agency: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.268, 84.033, 84.038, 84.063, and 84.379 Program: Student Financial Assistance Programs Cluster Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS or Clearinghouse) that DOE considers high risk. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The College?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the College?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management's Response: In previous submission of these students' graduation status, errors in the Alverno dataset resulted in accurate transmissions to the Clearinghouse in some cases. Since that time, we have improved our review process. Our current process involves a collaboration between the Registrar and Senior Data Specialist on the Institutional Research team within our Assessment and Outreach Center to ensure that the number of graduating records matches in all reporting processes. This double review provides another opportunity to find and correct enrollment errors before submitting the files to the Clearinghouse. Additionally, the Senior Data Specialist carefully reviews all errors returned by the Clearinghouse and makes corrections to the records as needed to ensure that completions are correctly applied. Finally, campus wide processes to verify enrollment at census and creation of standardized calendar dates have been implemented to reduce the opportunities for data error.