Finding 1167578 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-02
Audit: 378700
Organization: Eastern Wyoming College (WY)

AI Summary

  • Core Issue: Significant deficiencies in reporting student enrollment status, leading to inaccuracies that could affect financial aid.
  • Impacted Requirements: Non-compliance with federal regulations regarding timely and accurate enrollment reporting as outlined in 34 CFR and NSLDS guidelines.
  • Recommended Follow-Up: Enhance controls in the Student Financial Aid and Registrar Offices and conduct direct reviews of enrollment status changes at NSLDS.

Finding Text

2025-001: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency) Assistance Listing Numbers/Titles: #84.268, Federal Direct Student Loans, and #84.063, Federal Pell Grant Program Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year: July 1, 2024 - June 30, 2025 Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information, including that previously provided by the student and the institution.” Per 34 CFR 685.309(b), “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.” Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.” Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.” Condition/context: Of the 11 students selected for testing of accurate enrollment reporting, we noted the following errors: • One instance in which the student was reported as withdrawn with the incorrect effective date; • Two instances in which the student was not reported within 60 days of the date of determination; and • One instance in which the student was reported with the incorrect enrollment status. Cause: The Student Financial Aid and Registrar Offices do not have sufficient controls in place to ensure the proper and timely reporting of student status changes. Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status. III. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS, Continued Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-002. Recommendation: The Student Financial Aid and Registrar Offices should implement additional controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.

Corrective Action Plan

The independent auditor identified certain concerns as set forth in the SFA Enrollment Reporting Control Deficiency, dated June 30, 2025. All concerns appear to relate to mid-semester withdrawals of students; all will be resolved by the continued implementation of previous corrective action plan (CAP) and the facilitation of the additional plan details set forth herein. As background to these issues, Eastern Wyoming College (EWC) experienced unique circumstances related to the transmission of student information as a result of its status on Heightened Cash Monitoring (HCM2). Simply, the systems in place between the college, the federal government, and a third-party vendor did not communicate accurately, principally due to timing issues of student information and EWC's requests for reimbursement of financial aid. In the previous audit (2023-24), these types of issues were identified and remedied through EWC's corrective action plan. At that time, EWC committed to manually updating the Clearinghouse/NSLDS systems to ensure timely enrollment reporting. This effort was put in motion beginning in October 2024. EWC submits the concerns identified in the latest report were largely being corrected by the previous plan and the resolution of the timing issues due to EWC's move from HCM2 to HCM1 statuses. As part of EWC's continued effort, it is worthwhile to note additional information, issues and resolutions. Enrollment reporting at EWC has been historically managed by the Data Analyst. This singular reporting has allowed data to be reported consistently and efficiently. However, because the analyst does not work in either the Registrar or Financial Aid Offices, the reporting has not been able to adeptly identify and address unusual cases. The current reporting structure requires additional review and oversight. Therefore, as part of corrective actions, the Registrar or designee will manage enrollment statuses for all mid-semester college withdrawals. The Registrar is in the best position see the student's enrollment and to identify the accurate dates. The Registrar will be the final decision maker regarding the reporting of information. In addition, the Financial Aid Office, as part of their R2T4 calculation checklist when an official withdrawal form exists, will ensure that any completed courses from Block A do not impact the student's reported status of withdrawn. The Financial Aid Director, either as part of the initial calculation or the follow-up internal audit, will confirm whether any credits are earned prior to a student's withdrawal. Further, the director will ensure that any withdrawal is separately reported because current, standard reporting may not identify this status change. Delayed reporting as noted in the associated finding, will no longer be an issue now that all systems are aligned following the college's move from HCM2 to HCM1 status. This allows National Student Loan Data System (NSLDS) to be notified of awarded aid, which will then allow the National Student Clearinghouse to effectively report all students, as required. In addition to the systems working as designed, EWC will conduct an internal audit each semester and will review students who withdrew during the term to ensure that all systems were updated correctly, and all offices reported accurate dates. In addition, all offices involved will create a collective Standard Operating Procedure manual related to enrollment reporting in addition to each office's separately documented procedures. Anticipated Completion Date: September 2025 Contact Person: Rebecca McAllister/Xi Feng/Dave Bluemel

Categories

Student Financial Aid

Other Findings in this Audit

  • 1167577 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $1.11M
84.268 FEDERAL DIRECT STUDENT LOANS $458,180
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $345,816
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $168,573
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $88,205
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $28,549
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $16,866
84.033 FEDERAL WORK-STUDY PROGRAM $14,679
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $10,593
17.259 WIA YOUTH ACTIVITIES $10,318