Audit 402343

Finding 2025-001 Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education – Student Financial Assistance Cluster Federal Direct Student Loans (Federal Assistance Listing #84.268) Federal Award Number: P268K251830 Federal Pell Grant Program (Federal Assistance Listing #84.063) Federal Award Number: P063P241830 Federal Award Year: 2024-2025 Criteria or Specific Requirement Institutions submit Direct Loan, Pell Grant, TEACH Grant and IASG origination records and disbursement records to the Common Origination and Disbursement (“COD”) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Condition In a non-statistical sample of 40 disbursements, the disbursement dates reported to the COD system for 28 disbursements differed from the dates of when Federal Direct Student Loans or Federal Pell Grants were credited to the respective students’ accounts as shown on the students’ account statements. Cause The errors were due to administrative oversight. Effect The disbursement dates for 28 disbursements were not accurately reported to the COD system. Questioned Costs None. Identification as a Repeat Finding Yes; see finding 2024-001 in the 2024 Single Audit report. Recommendation The College should implement procedures to ensure that students’ disbursement dates for Federal Direct Student Loans and Federal Pell Grants are reported to the COD system accurately. Views of Responsible Officials and Corrective Actions See Corrective Action Plan.

Finding 2025-002 Special Tests and Provisions – NSLDS Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education – Student Financial Assistance Cluster Federal Direct Student Loans (Federal Assistance Listing #84.268) Federal Award Number: P268K251830 Federal Pell Grant Program (Federal Assistance Listing #84.063) Federal Award Number: P063P241830 Federal Award Year: 2024-2025 Criteria or Specific Requirement Institutions are required to report enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan (“FFEL”) programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify 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 website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. Institutions are responsible for accurately reporting all Campus-Level Record data elements. The Campus-Level Record data elements that the U.S. Department of Education considers to be high risk include: • Enrollment effective date; • Enrollment status; • OPEID number; and, • Certification date. Institutions are responsible for accurately reporting all Program-Level Record data elements. The Program-Level Record data elements that the U.S. Department of Education considers to be high risk include, but are not limited to: • Program enrollment effective date; • Published program length; • Program begin date; • Program enrollment status; and, • Classification of Instructional Program (“CIP”) code. The enrollment effective date represents the date that the current enrollment status reported for a student was first effective. The program enrollment effective date represents the date when the student’s current program status took effect. Context and Condition For a non-statistical sample of 40 students, we identified the following instances of noncompliance: 1) For one student who withdrew during the 2024-2025 academic year and for two students who had achange in attendance levels that impacted their enrollment status, the enrollment effective dates for suchenrollment status changes reported on their NSLDS Campus-Level records did not reflect the dates thatthe enrollment status changes for the students were first effective based on the students’ enrollmentrecords. 2) For one student who withdrew during the 2024-2025 academic year and for two students who had achange in attendance levels that impacted their enrollment status, the program enrollment effective datesfor such enrollment status changes reported on their NSLDS Program-Level records did not reflect thedate when the students’ current program status took effect based on the students’ enrollment records. Cause The errors in the reporting of enrollment effective dates and program enrollment effective dates were due to administrative oversight. Effect The enrollment effective date and program enrollment effective date for three students were not accurately reported to the NSLDS. Questioned Costs None noted. Identification as a Repeat Finding This is not a repeat finding. Recommendation The College should implement procedures to ensure that students’ enrollment effective dates and program enrollment effective dates are reported to the NSLDS accurately and in accordance with the requirements in the NSLDS Enrollment Guide. Views of Responsible Officials See Corrective Action Plan.