Finding 1172439 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-04
Audit: 385572
Organization: Bay De Noc Community College (MI)

AI Summary

  • Core Issue: The College failed to report a student's enrollment status change to NSLDS within the required 60 days.
  • Impacted Requirements: This noncompliance violates 34 C.F.R. §685.309 and NSLDS Enrollment Reporting requirements.
  • Recommended Follow-Up: Update enrollment reporting processes to include all students, especially those with unique coding, and implement controls to ensure timely reporting.

Finding Text

2025-002 - Noncompliance with Enrollment Status Change Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268; Award Numbers P007A231980, P007A241980, P033A241980, P063P231624, P063P241624. Criteria. Per 34 C.F.R. §685.309 and NSLDS Enrollment Reporting requirements, institutions must report accurate and complete student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of becoming aware that a student’s enrollment status has changed. Condition. During our testing of enrollment status change reporting, we noted one instance in which a student’s status change was not reported to NSLDS within 60 days. Cause. The delay occurred because the student was assigned a different coding structure within the College’s system due to their foreign student status. This coding difference resulted in the student being excluded from the standard status-change reporting process, causing the change to be overlooked when NSLDS reporting was performed. Effect. As a result of this condition, the College was out of compliance with enrollment reporting requirements. Questioned Costs. No costs are requried to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students, including those with unique or foreign-student coding, are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. View of Responsible Officials. Management agrees with the finding and has updated internal reports and review procedures to ensure all student types are included in enrollment reporting workflows. Management has prepared a corrective action plan.

Corrective Action Plan

Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding structure within the College's system which resulted in the student being excluded from the standard status-change reporting process. As a result of university personnel using the incorrect semester start dates. As a result of this condition, the College was temporarily out of compliance with enrollment reporting requirements. Auditor Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students-including those with unique or foreign-student coding-are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. Corrective Action. Bay College took swift action after determining some students were being excluded in our enrollment reporting. Our reporting process was excluding students who were noted as being a citizen of a foreign county. We now review these students prior to each reporting cycle to determine if they should be included in the reporting. The Financial Aid team reviews this report to determine if the student is eligible for federal student aid. Students who are eligible are indicated and provided to the Institutional Effectiveness team to include in the enrollment reporting. This process is completed prior to each reporting cycle. For students who were not included in our prior reporting, the Financial Aid team working directly with the Institutional Effectiveness team, determined which should be reported and completed their enrollment reporting directly through NSLDS. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. June 30, 2026

Categories

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring Allowable Costs / Cost Principles Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1172433 2025-002
    Material Weakness Repeat
  • 1172434 2025-002
    Material Weakness Repeat
  • 1172435 2025-002
    Material Weakness Repeat
  • 1172436 2025-002
    Material Weakness Repeat
  • 1172437 2025-002
    Material Weakness Repeat
  • 1172438 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $3.44M
84.268 FEDERAL DIRECT STUDENT LOANS $2.56M
84.042 TRIO_STUDENT SUPPORT SERVICES $375,352
84.033 FEDERAL WORK-STUDY PROGRAM $160,079
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $70,029
10.217 HIGHER EDUCATION - INSTITUTION CHALLENGE GRANTS PROGRAM $36,043
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $9,800
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $9,196