Finding Text
FINDING 2024-003 – Enrollment Reporting
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with
deadline dates established by the Secretary, through publication in the Federal Register, other reports
and information the Secretary requires and shall comply with the procedures the Secretary finds
necessary to ensure that the reports are correct.
The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized
database for students’ enrollment information. It is the College’s responsibility to update this information
timely and accurately.
The College determines how often it receives the Enrollment Reporting roster file with the default set at
every 60 days.
Condition and context: 2 submissions of withdrawal were reported late and not identified prior to
submission. 20 students were sampled using a random sampling methodology, from a population of 42
withdrawals, and 244 graduates.
Questioned costs: None.
Effect: This information is utilized by the Department of Education, the Federal Direct Loan program,
lenders, and other institutions to determine in-school status. However, American Samoa Community
College doesn’t participate in loan programs, which limits the effect of non-compliance.
Cause: In fiscal year 2024, the College implemented many new controls which were communicated in the
previous corrective action in the preceding year. One control that was not implemented until May 2024
was the control related to the review by the Financial Aid Manager of the prepared Roster File prior to
submission. We noted that the control was operating as designed post implementation. The College’s
policy was not adhered to between October 2023 and May 2024 and as such was the control was not
operating as intended during that period.
Repeat finding: Yes.
Recommendation: We recommend that the College ensure the policy is being followed which requires a
review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we
recommend the College retain documentation reflecting all formal reviews of the roster. This
Recommendation: We recommend that the College ensure the policy is being followed which requires a
review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we
recommend the College retain documentation reflecting all formal reviews of the roster. This
recommendation was made in the prior year and correction occurred during the current fiscal year; we
noted that the control was operating as designed post implementation in May 2024.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs