Finding 1170880 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-29

AI Summary

  • Core Issue: The College lacks controls to review student enrollment status changes submitted to the NSLDS, risking inaccurate reporting.
  • Impacted Requirements: Compliance with federal regulations requires timely and accurate reporting of enrollment changes within 60 days.
  • Recommended Follow-Up: Implement an independent review process for NSLDS submissions to ensure accuracy and compliance.

Finding Text

2025-001: Enrollment Reporting Controls– Student Financial Aid Special Test Material Weakness Federal Program: Student Financial Assistance Cluster Federal Agency: Department of Education Federal Award Year: July 1, 2024 - June 30, 2025 Assistance Listing Number(s): Student Financial Assistance Cluster • 84.007 • 84.033 • 84.038 • 84.063 • 84.268 • 84.379 • 93.925 Criteria: To comply with enrollment reporting requirements, institutions must accurately and timely report student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of determining the change, as outlined in Federal Regulations 34 CFR 682.610 and 685.309. Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There is no control in place by the College to review information submitted to the NSLDS for student enrollment status changes. The individual performing the submission is able to complete and transmit the data without an independent review or verification by another person, increasing the risk of inaccurate or incomplete information being reported. Cause: Lack of control in place over enrollment status changes reported to the NSLDS. Effect or Potential Effect: Lack of controls in place could result in instances of noncompliance with Department of Education and Federal regulations. Questioned Costs: None Context: While the College ensures accurate status change data is sent to the National Student Clearinghouse (third party who submits enrollment status changes to the NSLDS), the College does not have controls in place to ensure information was submitted to the NSLDS accurately and timely. Repeat Finding: Yes Recommendation: We recommend the College implement controls where there is an independent review of the submissions received by NSLDS to ensure enrollment status changes are reported accurately and timely. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure accurate and timely enrollment reporting while maintaining operational efficiency. Effective immediately, the College will implement the following controls: 1. Continued Use of the National Student Clearinghouse (NSC) The College will continue to rely on the National Student Clearinghouse as its third-party servicer for enrollment status reporting to NSLDS. 2. Independent Post-Submission Review On a monthly basis, the Office of Financial Aid will review NSC enrollment reporting confirmation files to verify that enrollment status changes were submitted to NSLDS accurately and within the required 60-day timeframe. This review will be performed by an individual other than the primary preparer, where feasible, or through supervisory review when staffing is limited. 3. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained. A simple enrollment reporting review log will be maintained to document compliance. 4. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to confirm controls are operating as intended. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: February 1, 2026 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been initiated. While formal independent review controls were not documented during the audit period, there were no identified instances of late enrollment reporting or inaccurate enrollment status submissions to NSLDS. The corrective actions above are intended to formalize controls and ensure sustained compliance with federal requirements.

Categories

Matching / Level of Effort / Earmarking Student Financial Aid Allowable Costs / Cost Principles Material Weakness Reporting

Other Findings in this Audit

  • 1170874 2025-001
    Material Weakness Repeat
  • 1170875 2025-001
    Material Weakness Repeat
  • 1170876 2025-001
    Material Weakness Repeat
  • 1170877 2025-001
    Material Weakness Repeat
  • 1170878 2025-001
    Material Weakness Repeat
  • 1170879 2025-001
    Material Weakness Repeat
  • 1170881 2025-002
    Material Weakness Repeat
  • 1170882 2025-002
    Material Weakness Repeat
  • 1170883 2025-002
    Material Weakness Repeat
  • 1170884 2025-002
    Material Weakness Repeat
  • 1170885 2025-002
    Material Weakness Repeat
  • 1170886 2025-002
    Material Weakness Repeat
  • 1170887 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $9.45M
84.063 FEDERAL PELL GRANT PROGRAM $2.80M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $910,953
93.925 SCHOLARSHIPS FOR HEALTH PROFESSIONS STUDENTS FROM DISADVANTAGED BACKGROUNDS $579,243
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $341,084
84.033 FEDERAL WORK-STUDY PROGRAM $255,310
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $168,235
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $90,420
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $44,044
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $12,748
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $7,444
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $3,772