Finding 1166272 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-23

AI Summary

  • Core Issue: Inaccurate and untimely reporting of student status changes to NSLDS, including withdrawals and graduation statuses.
  • Impacted Requirements: Non-compliance with 34 CFR 690.83 and 34 CFR 685.309 regarding timely and accurate reporting.
  • Recommended Follow-Up: Implement consistent controls in the Student Financial Aid Office and Records and Registration to ensure compliance and accurate reporting.

Finding Text

Criteria: Per 34 CFR 690.83, 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 in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary. Condition/context: Of the 17 students selected for testing: • One student’s withdrawn status was not reported to NSLDS. • One graduated student was not reported properly as such at the Campus Level. • Five students were not reported to NSLDS with an accurate withdrawal date. • Two students’ status changes were not reported within 60 days of the date of determination. • Two students’ program start dates were not reported accurately. Cause: The Student Financial Aid Office and Records and Registration do not have consistent controls in place to ensure the proper and timely reporting of student status changes. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-005. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.

Corrective Action Plan

Western Wyoming Community College experienced a transition in leadership within the Financial Aid Office, resulting in a change in the Director of Financial Aid position. This transition caused disruptions in communication and process continuity between the Financial Aid, Registrar, and Institutional Effectiveness offices. As a result, inconsistencies were identified in the timing and accuracy of enrollment reporting to the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS). Corrective Action Plan 1. Leadership and Process Realignment a. A new Director of Financial Aid has been appointed and is collaborating with the Institutional Effectiveness Office and the Registrar to define clear processes and timelines for Records & Registration and Financial Aid operations. b. The Director of Financial Aid and Registrar will maintain continuous communication to ensure timely and accurate enrollment reporting and prompt correction of any identified discrepancies. c. The Director of Financial Aid and Registrar will work together to develop a Standard Operating Process (SOP) to ensure if any future attrition occurs in either department that anyone else in those departments will be able to step in and continue processing without interruption ensuring timely and accurate enrollment reporting continues. 2. Implementation of Controls for Third-Party Reporting a. Recognizing the benefits and responsibilities of using the National Student Clearinghouse (NSC) for enrollment reporting, the institution has implemented controls to verify the accuracy of data transmitted through this third-party servicer. b. The Assistant Director (or the Director of Financial Aid in the Assistant Director’s absence) will generate the Summary Return of Funds Report (ROFS) from Colleague each term and provide a copy to the Registrar for enrollment verification and reconciliation. 3. Quarterly Reconciliation and Internal Review a. The Financial Aid Office will conduct a quarterly comparison between Colleague and NSLDS records to ensure consistency of enrollment and status dates. b. Any discrepancies identified will be communicated to the Registrar for prompt resolution. c. Results of the quarterly reviews will be documented and used for internal compliance monitoring and training. 4. Updated End-of-Term Procedure To ensure ongoing accuracy and compliance, the following revised steps will be followed each term: a. The Director or Assistant Director of Financial Aid will run an All F Report after final grades are posted. b. The Director and Assistant Director of Financial Aid will jointly calculate Return to Title IV (R2T4) funds. c. The Return of Funds Report (ROFS) will be provided to the Registrar monthly to verify last date of attendance and withdrawal dates against Colleague records. d. The Registrar will verify subsequent semester enrollments and continuously monitor student enrollment, reporting any changes to Financial Aid leadership. e. The Registrar will submit end-of-term enrollment data to the National Student Clearinghouse as usual, and one week before the next term begins, will submit the end-of-term R2T4 list to prevent overwriting by subsequent semester reporting. 5. Training and Internal Audit Enhancement a. The Financial Aid and Registrar’s Offices will use findings from this audit to develop staff training on identifying and correcting data discrepancies during the quarterly reconciliation process. b. The Director of Financial Aid will review 80% of R2T4 files during each semester for accuracy in reporting and documentation. 6. Graduation Data Accuracy a. The Registrar’s Office utilizes the Update Academic Credentials File (UACF) in Colleague to batch post student degrees and certificates three times per year (end of spring, summer, and fall terms). b. It was determined that the automatic graduation date populates correctly only when students have a single program with no changes. For students with multiple programs or program changes, the graduation date must be entered manually to ensure accuracy. c. The Registrar will oversee the upload of graduates and verification of accurate credential dates, ensuring these dates are correctly reflected in NSC and the Director or Assistant Director of Financial Aid will make sure the dates are correctly reflected in the NSLDS system. d. The Registrar and Director of Financial Aid will conduct joint reviews to verify that all graduation and enrollment data are reported correctly. Anticipated Completion Date: June 30, 2026 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, and Kayla Miller, Registrar

Categories

Student Financial Aid Eligibility Period of Performance Reporting

Other Findings in this Audit

  • 1166269 2025-001
    Material Weakness Repeat
  • 1166270 2025-002
    Material Weakness Repeat
  • 1166271 2025-003
    Material Weakness Repeat
  • 1166273 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $2.64M
84.268 FEDERAL DIRECT STUDENT LOANS $1.57M
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $635,589
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $253,998
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $247,937
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $119,842
47.076 EDUCATION AND HUMAN RESOURCES $63,041
84.051 CAREER AND TECHNICAL EDUCATION -- NATIONAL PROGRAMS $39,966
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $32,535
84.033 FEDERAL WORK-STUDY PROGRAM $24,001
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $13,583
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $8,430