Finding Text
Criteria Requirement:
According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must
complete and return the Enrollment Reporting roster file via National Student Loan Data System
(NSLDS) within 15 days of receipt. 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.
Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non_x0002_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
the 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 and Context:
During our audit we found three (3) of forty (40) students selected for testing whose change in
enrollment status from full time to withdrawn was not transmitted to NSLDS timely. The College
reported the withdrawn status changes for these three students 61-65 days after they became aware
of the status change. In addition, of these three students, the effective dates for two of the students
were reported as 12/15/2023, however the effective date per supporting documentation was
12/16/2023.
Cause and Effect:
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.
Inaccurate and delayed submission of student enrollment status information affects the determinations
that lenders and servicers 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.
Identification of Questioned Costs:
None.
Whether the Sampling was a Statistically Valid Sample:
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding:
This is not a repeat finding.
Recommendation:
We recommend that the College review its processes to ensure that all enrollment changes are
reported as intended within the required 60-day time frame. The College should work with NSC as
needed to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the
submitted enrollment changes to the NSLDS should be performed to ensure current student status is
properly reflected.