Finding 1165652 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-19
Audit: 376312
Organization: Berry College (GA)
Auditor: BDO USA PC

AI Summary

  • Core Issue: One student's Program-Level enrollment data was incorrectly reported to NSLDS, specifically the Program Begin Date.
  • Impacted Requirements: Institutions must accurately report enrollment information, including the correct Program Begin Date, as per federal guidelines.
  • Recommended Follow-Up: Enhance procedures for enrollment reporting and verify that Program Begin Dates align with the actual start of the academic term.

Finding Text

Finding 2025-003 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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. The data on the institution’s 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,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: For 1 student selected for testing, certain key elements at the Program-Level were not correctly reported to the NSLDS. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with the requirements of Program-Level enrollment reporting. Questioned Costs: $0 Context: 1 out of 25 students selected for testing. Identification of Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Management agrees with the finding that one student’s Program Begin Date was incorrectly reported to NSLDS. For this new student, the Program Begin Date was reported as 5/14/2021, the date the new student transitioned from admissions to registration, rather than the actual first day of the academic term in which the student began enrollment in the program, as required by Part 5 of the 2025 Compliance Supplement. Beginning with the 2020 OMB Compliance Supplement, enrollment reporting requirements were expanded to include additional compliance data elements for NSLDS. During the 2020-2021 award year, the National Student Clearinghouse (NSC), the College’s third-party servicer for enrollment reporting, encountered program level data integrity issues. In response, new warning codes were introduced in December 2021, including WC 1811 Series, which addresses mismatch flags in Program Begin Date. In this case, however, no warning flag was triggered for the student. The Registrar Office will follow up with NSC to identify why the warning flag did not trigger. Moving forward, Registrar Office staff will review enrollment reporting files to verify that each student’s Program Begin Date reflects the first day of the term in which the program enrollment began, unless the student’s enrollment in the program was on an earlier date.

Corrective Action Plan

Finding 2025-003 Name of Responsible Individual: Bryce Durbin, Director of Institutional Research & Registrar Corrective Action Plan: Management agrees with the finding that one student’s Program Begin Date was incorrectly reported to NSLDS. For this new student, the Program Begin Date was reported as 5/14/2021, the date the new student transitioned from admissions to registration, rather than the actual first day of the academic term in which the student began enrollment in the program, as required by Part 5 of the 2025 Compliance Supplement. Beginning with the 2020 OMB Compliance Supplement, enrollment reporting requirements were expanded to include additional compliance data elements for NSLDS. During the 2020-2021 award year, the National Student Clearinghouse (NSC), the College’s third-party servicer for enrollment reporting, encountered program level data integrity issues. In response, new warning codes were introduced in December 2021, including WC 1811 Series, which addresses mismatch flags in Program Begin Date. In this case, however, no warning flag was triggered for the student. The Registrar Office will follow up with NSC to identify why the warning flag did not trigger. Moving forward, Registrar Office staff will review enrollment reporting files to verify that each student’s Program Begin Date reflects the first day of the term in which the program enrollment began, unless the student’s enrollment in the program was on an earlier date. Anticipated Completion Date: December 31, 2025

Categories

Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1165644 2025-001
    Material Weakness Repeat
  • 1165645 2025-001
    Material Weakness Repeat
  • 1165646 2025-001
    Material Weakness Repeat
  • 1165647 2025-001
    Material Weakness Repeat
  • 1165648 2025-001
    Material Weakness Repeat
  • 1165649 2025-002
    Material Weakness Repeat
  • 1165650 2025-002
    Material Weakness Repeat
  • 1165651 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $9.08M
84.063 FEDERAL PELL GRANT PROGRAM $4.78M
93.493 CONGRESSIONAL DIRECTIVES $645,872
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $463,748
84.033 FEDERAL WORK-STUDY PROGRAM $309,837
84.042 TRIO STUDENT SUPPORT SERVICES $304,756
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $153,355
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $38,052
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $26,395
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $15,088
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $0