Finding 1102774 (2024-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-08
Audit: 345265
Organization: Greenfield Community College (MA)

AI Summary

  • Core Issue: The College failed to report student enrollment changes accurately and on time to the NSLDS, affecting loan grace periods.
  • Impacted Requirements: Reporting errors included incorrect effective dates and statuses for 12.5% and 10% of students, respectively, violating federal regulations.
  • Recommended Follow-Up: Provide targeted training for staff on NSLDS reporting rules, focusing on accurate effective dates and the implications of errors.

Finding Text

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 5 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS, 4 students, out of a sample of 40, that had an incorrect student status and 4 students, out of sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS and within the required timeframe. Effect The College did not report the students’ correct effective dates to NSLDS and within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 5 students, or 12.5% of our sample, had incorrect effective dates reported to NSLDS, 4 students, or 10% of our sample, had an incorrect student status and 4 students, or 10% of our sample, were not reported to NSLDS within the required timeframe. Identification as a Repeat Finding, if applicable Yes, see finding 2023-001. Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. View of Responsible Officials The College agrees with the finding.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 526332 2024-001
    Significant Deficiency Repeat
  • 526333 2024-001
    Significant Deficiency Repeat
  • 526334 2024-002
    Significant Deficiency Repeat
  • 1102775 2024-001
    Significant Deficiency Repeat
  • 1102776 2024-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $2.40M
84.268 Federal Direct Student Loans $515,560
21.027 Coronavirus State and Local Fiscal Recovery Funds $149,202
84.033 Federal Work-Study Program $148,196
84.048 Career and Technical Education -- Basic Grants to States $127,181
17.261 Workforce Data Quality Initiative (wdqi) $69,216
84.007 Federal Supplemental Educational Opportunity Grants $56,043
84.425 Education Stabilization Fund $45,363
93.493 Congressional Directives $13,741
84.116 Fund for the Improvement of Postsecondary Education $7,597