Finding 1168610 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-09
Audit: 380523
Organization: Welch College (TN)
Auditor: CROSSLIN PLLC

AI Summary

  • Core Issue: One out of three student status changes was not reported to NSLDS on time.
  • Impacted Requirements: NSLDS mandates reporting changes within 30 days or 60 days if a roster file is expected.
  • Recommended Follow-Up: Improve procedures to ensure timely reporting of all student status changes to NSLDS.

Finding Text

ITEM # 2025 - 001 - INTERNAL CONTROLS OVER STUDENT’S CHANGE IN STATUS FOR SPECIAL TESTS AND PROVISIONS Student Financial Assistance Cluster U.S. Department of Education Criteria The National Student Loan Data System (“NSLDS”) requires the College to report student enrollment changes within 30 days of the change in status, however, if a roster file is expected within 60 days, a 60-day time frame is allowable. Condition and Context In testing the internal controls for Welch’s major program, it was noted that there was one selection out of three selections tested where the student’s status change was not reported with the NSLDS within the allowable time frame. Cause The student was not properly included in the Populi system as withdrawn which resulted in the error not being discovered until after the allowable time frame had passed. Effect Welch was not in compliance with NSLDS reporting requirements. Recommendation We recommend that Welch strengthens procedures to ensure all status changes are reported within the required time frame to NSLDS.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions Clearinghouse reports are from the college’s student information system (SIS). During FY24, the finding stems from a student’s withdrawal, which was promptly processed and entered in the SIS. However, the system categorized the student as "less than half-time” because the student received a passing grade in a course for which the student was exempted after passing a proficiency test. The SIS did not update the student status to 'withdrawn' until the semester ended, which was more than 60 days after the withdrawal date. To remedy this issue, the college’s Business Office now maintains an online spreadsheet listing withdrawn students outside the SIS that is updated whenever a student withdraws from the college. The list has been shared with the personnel responsible for the Clearinghouse reports and the Financial Aid Coordinator. Personnel will monitor the withdrawal listing and verify that all withdrawn students are accurately categorized in the Clearinghouse report from the SIS before completing the submission. After reviewing the FY25 finding, we discovered that the student attended in the spring 2025 semester but withdrew during the college’s drop/add period. By default, the SIS removes students who withdraw during drop/add from the Clearinghouse report.We have confirmed that Welch is unable to modify data or correct errors in the SIS report submitted to the Clearinghouse.Action Taken/Planned To address these problems, which ultimately stemmed from the limitations of Clearinghouse reporting by the college’s SIS, Welch has taken the following steps: 1. Clearinghouse reporting responsibilities have transitioned to a full-time, onsite employee in the Provost’s Office. 2. When preparing Clearinghouse reports and to help with identifying any errors before submitting the report, the employee will continue to monitor the withdrawn students listing maintained by the college’s Business Office, as outlined in the steps taken with the FY24 finding. 3. Welch plans to engage with its SIS and explain the reporting issues and limitations to determine if the SIS can help the college resolve the reporting limitations with its system. 4. To minimize the possibility of students being omitted from any Clearinghouse report, the employee responsible for the Clearinghouse report will submit an initial report to Clearinghouse on the first day of each term (fall, winter, spring, summer), followed by submitting reports on the mandatory reporting dates, as given by Clearinghouse. 5. The employee responsible for Clearinghouse reporting and the college’s Financial Aid Coordinator will collaborate before and after each Clearinghouse submission, and once the submission data is reported to NSLDS by Clearinghouse, the Financial Aid Coordinator will review all withdrawn students to confirm their NSLDS status is correct. If not, she will manually update the student’s NSLDS status to ensure accuracy. Anticipated Completion Date/Date Completed: November 6, 2025

Categories

Special Tests & Provisions Student Financial Aid Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $653,216
84.063 FEDERAL PELL GRANT PROGRAM $609,588
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $15,611
84.033 FEDERAL WORK-STUDY PROGRAM $13,037