Audit 396193

Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via the National Student Loan Data System (NSLDS) within the timeframe prescribed by the Secretary. Unless the institution plans to submit its next updated enrollment report to the Secretary within 60 days, a school must notify the Secretary within 30 days after the date that the school discovers a change. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days to ensure attendance changes for students are reported within 60 days of the change. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half -time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Internal controls 2 CFR 200.303(a) states the 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 statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition During our audit we found one (1) of forty (40) students selected for testing whose enrollment status was not timely transmitted to NSLDS. KPMG notes that for this exception, the student’s enrollment status was never reported to NSLDS although the College was aware of their enrollment status. Because the College did not have a significant number of students impacted by the specific cause for the exception noted, the noncompliance is not a reportable finding. However, the College did not have a control in place to identify errors in enrollment status transmissions and this control deficiency is considered to be a significant deficiency. Cause The condition resulted from the College’s internal controls not being designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Possible Asserted Effect Not identifying inaccurate, delayed, or lack of submission of student enrollment status information could have impacted the determinations that lenders and services of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The conditions found do not constitute a repeat finding from the prior year. Recommendation We recommend that the College review its processes to ensure that appropriate controls are put in place to identify any errors in the reporting of enrollment changes. Views of College Officials Recommendation accepted. Please refer to corrective action plan.