Finding Text
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must accurately report the enrollment status of all students regardless of whether they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reporting for both the Campus-Level and the Program-Level, as well as the program begin date. 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. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 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). Additionally, the College did not have a control process in place to ensure timely and accurate reporting. Questioned Costs: None. Context: In our statistically valid sample of 60 students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 22 students that had the campus enrollment status reported incorrectly, 24 students had incorrect enrollment effective date, 60 students were reported past the 60-day reporting timeframe, 60 students were not certified every 60 days, five students had no record listed in NSLDS, three students where NSLDS Program enrollment effective date did not match the institutions records, two students where the students NSLDS Program enrollment status did not match the institutions records, one student had incorrect program length, and one student had a program begin date that did not match institutional records. Additionally, there was no review process to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institution’s 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. 2023-004. Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as retaining evidence of this control being performed. Views of responsible officials: There is no disagreement with the finding.