Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268
Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution’s prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period.
Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022 and controls in place did not identify the excess cash. The maximum daily excess cash balance during this time-period was $51,701.
Questioned Costs: None
Prevalence: Identified in 1 out of 15 disbursements tested during the June 30, 2022 audit. The sample was not intended to be, and was not, a statistically valid sample. Our testing during the June 30, 2023 audit did not identify any amount of excess cash remaining in the College’s account after September 20, 2022.
Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)).
Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe.
Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met.
Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions were made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063
Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC).
Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award.
Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 5 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The students’ status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred between 70 and 161 days for the five students from the date of status change.
Questioned Costs: None.
Prevalence: Identified in 5 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample.
Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Cause: The College’s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS.
Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected.
Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063
Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC).
Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award.
Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 5 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The students’ status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred between 70 and 161 days for the five students from the date of status change.
Questioned Costs: None.
Prevalence: Identified in 5 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample.
Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Cause: The College’s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS.
Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected.
Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event.
Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event.
Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023.
Cause: Lack of procedures in place to identify triggering events that require reporting to the ED.
Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding.
Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner.
Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268
Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution’s prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period.
Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022 and controls in place did not identify the excess cash. The maximum daily excess cash balance during this time-period was $51,701.
Questioned Costs: None
Prevalence: Identified in 1 out of 15 disbursements tested during the June 30, 2022 audit. The sample was not intended to be, and was not, a statistically valid sample. Our testing during the June 30, 2023 audit did not identify any amount of excess cash remaining in the College’s account after September 20, 2022.
Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)).
Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe.
Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met.
Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions were made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063
Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC).
Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award.
Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 5 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The students’ status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred between 70 and 161 days for the five students from the date of status change.
Questioned Costs: None.
Prevalence: Identified in 5 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample.
Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Cause: The College’s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS.
Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected.
Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063
Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC).
Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award.
Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 5 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The students’ status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred between 70 and 161 days for the five students from the date of status change.
Questioned Costs: None.
Prevalence: Identified in 5 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample.
Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Cause: The College’s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS.
Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected.
Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.