Finding 1165434 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-18
Audit: 376138
Auditor: EIDE BAILLY LLP

AI Summary

  • Core Issue: The District is not complying with federal enrollment reporting requirements due to inaccuracies in effective dates reported to NSLDS for 9 out of 60 students.
  • Impacted Requirements: Institutions must accurately report both "Campus Level" and "Program Level" enrollment information, including effective dates, as per the OMB Compliance Supplement.
  • Recommended Follow-Up: Implement controls and system improvements to ensure accurate reporting of effective enrollment status change dates to NSLDS.

Finding Text

Criteria OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: 9 of 60 students’ effective dates were not accurately reported in NSLDS (date of enrollment status change does not agree to effective date in the student records). o 2 students from Coastline College o 3 students from Golden West College o 4 students from Orange Coast College Questioned Costs There are no questioned costs associated with the condition identified. Context The District disbursed financial aid to approximately 9,812 students that required student enrollment and program enrollment reporting to NSLDS. A significant deficiency is a control weakness, or combination of weaknesses, that is less severe than a material weakness yet still affects federal compliance and is important enough to require the attention of management. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The effective date of enrollment status change reported to NSLDS was the system process date or report run date, rather than the actual effective date of the student’s enrollment status change as documented in the student’s records. Recommendation The District should implement controls to ensure effective dates of enrollment status changes are accurately captured and reported to NSLDS. Because this is a partially automated process through the District’s information systems, we recommend implementation of system improvements to ensure that the correct effective date, rather than the process or run date, is reported.

Corrective Action Plan

Views of Responsible Officials and Corrective Action Plan The District submits the file with the required enrollment information to the National Student Clearinghouse (NSC) two weeks after the start of each term and subsequently on a monthly basis. Part of the reporting process includes running SFRTMST, a baseline process in Ellucian Banner, the District’s Enterprise Resource Planning system, to calculate or update a student’s enrollment time status, which is the date when a change occurred in the enrollment of a student due to either registering in a class(es) or withdrawing from a class(es). The enrollment time status date is included in the enrollment file submitted to NSC. NSC then submits the enrollment information to the National Student Loan Data System (NSLDS). The discrepancy identified for the nine students was between a withdrawal date in Banner versus the enrollment time status date reported to NSC/NSLDS, which was the Banner calculated date. Because of the timing of when the SFRTMST process was ran, some students’ enrollment time status date did not match the registration activity date/enrollment effective date in Banner. After conducting research using the Ellucian Customer Center, the District identified a resolution to address this issue and has already implemented it for Fall 2025. To ensure that the students’ enrollment time status date reported to NSC/NSLDS matches the students’ effective date of their registration activity in Banner, the District activated the Calculate Time Status (Indicator) in SOATERM, a Banner setup, for Fall 2025 and will do so for all terms moving forward. Per Ellucian, when this indicator is set to “Y” a dynamic time status calculation will take place. The District verified that this process works. The issue has been resolved. In addition, the dates for the nine students were corrected in NSLDS. It is important to note that this issue has had no financial impact on the District. The students have been disbursed the correct amount of financial aid. The calculation of financial aid to be disbursed is not based on the enrollment dates reported to NSC and NSLDS.

Categories

Student Financial Aid Material Weakness Reporting Significant Deficiency

Other Findings in this Audit

  • 1165429 2025-001
    Material Weakness Repeat
  • 1165430 2025-001
    Material Weakness Repeat
  • 1165431 2025-001
    Material Weakness Repeat
  • 1165432 2025-001
    Material Weakness Repeat
  • 1165433 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $5.41M
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $1.69M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.50M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $1.06M
84.033 FEDERAL WORK-STUDY PROGRAM $916,332
84.425 EDUCATION STABILIZATION FUND $742,159
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $444,753
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $148,918
84.063 FEDERAL PELL GRANT PROGRAM $64,601
97.012 BOATING SAFETY FINANCIAL ASSISTANCE $59,301
12.905 CYBERSECURITY CORE CURRICULUM $39,542
84.031 HIGHER EDUCATION INSTITUTIONAL AID $34,052
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $18,401
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $11,478