Finding Text
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.