Audit 376138

Criteria OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: 9 of 60 students’ effective dates were not accurately reported in NSLDS (date of enrollment status change does not agree to effective date in the student records). o 2 students from Coastline College o 3 students from Golden West College o 4 students from Orange Coast College Questioned Costs There are no questioned costs associated with the condition identified. Context The District disbursed financial aid to approximately 9,812 students that required student enrollment and program enrollment reporting to NSLDS. A significant deficiency is a control weakness, or combination of weaknesses, that is less severe than a material weakness yet still affects federal compliance and is important enough to require the attention of management. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The effective date of enrollment status change reported to NSLDS was the system process date or report run date, rather than the actual effective date of the student’s enrollment status change as documented in the student’s records. Recommendation The District should implement controls to ensure effective dates of enrollment status changes are accurately captured and reported to NSLDS. Because this is a partially automated process through the District’s information systems, we recommend implementation of system improvements to ensure that the correct effective date, rather than the process or run date, is reported.