FAC Explorer

Finding 1172452 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-04
Audit: 385605
Organization: Occidental College (CA)
Auditor: BAKER TILLY US LLP

AI Summary

  • Core Issue: The College failed to report changes in student enrollment status to the NSLDS within the required timeframes, leading to inaccurate loan information.
  • Impacted Requirements: Compliance with 34 CFR section 685.309(b)(2) regarding timely notifications for enrollment changes.
  • Recommended Follow-Up: Implement processes to ensure timely updates to NSLDS for graduations and address changes, adhering to the 30-day and 60-day requirements.

Finding Text

Finding: 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (Please see SFQC - Section III - Finding 2025-001, for included table) Criteria: 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context: A sample of 20 out of a universe of 228 federal aid recipient students were selected from system generated reports of students who graduated, withdrew, or dropped during the 2024-2025 academic year. The enrollment information per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. All 20 of the students selected as samples were not reported to the NSLDS within the required timeframe. Cause: Capacity constraints and turnover within the registrar department limited the College’s ability to implement proper oversight of enrollment reporting. Effect or potential effect: The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Recommendation: We recommend that the College timely notify NSLDS of any changes of students’ status such as graduation, address change, etc. We recommend that the College updates NSLDS for any graduations within the 30-day requirement or include in a roster file within 60 days. Repeat Finding: Yes, see 2024-001. Management’s Response: The College has accepted the auditor recommendation that the College document and implement processes to ensure timely NSLDS reporting. A Corrective Action plan has been created.

Corrective Action Plan

OCCIDENTAL COLLEGE CORRECTIVE ACTION PLAN FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Explanation of Deficiency: A sample of 20 federal aid recipient students was selected fromsystem generated reports of students who graduated, withdrew, or dropped during the 2024-2025 academic year. The enrollment information per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. All 20 of the students selected as samples were not reported to the NSLDS within the required timeframe. Corrective Action Plan: With the hiring of our Associate Registrar for Systems and Reporting we once again have a staff member specifically responsible for reporting enrollment and degrees to the NSC. That position is backed up by three other staff members who also have access to submit and correct files. This past summer, we adjusted our reporting schedule in a further effort to comply with our reporting requirements. Despite any delays caused by us or by the National Student Clearinghouse, I understand that we are responsible for making sure our data is received and posted according to our obligations. The division of labor that comes with a full staff will allow for data transfers as soon as degrees are posted after the end of a semester. The adjusted timing for enrollment file submissions will also prevent any bottlenecks that might delay our data from being posted. These steps have already been implemented as evidenced by the fact that our degree file for the fall semester just ended was sent before our holiday break. As noted last year, staff have been instructed that the resolution of error files is to be given a high priority. One staff member has priority responsibility for resolving those files backed up by our primary submitter of data to the Clearinghouse. Contact Person Responsible for Corrective Action: James Herr, Occidental College Registrar Anticipated Completion Date: August 1, 2025

Categories

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1172448 2025-001
    Material Weakness Repeat
  • 1172449 2025-001
    Material Weakness Repeat
  • 1172450 2025-001
    Material Weakness Repeat
  • 1172451 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $7.73M
84.063 FEDERAL PELL GRANT PROGRAM $2.43M
84.038 FEDERAL PERKINS LOAN PROGRAM (BEGINNING OF THE YEAR) $1.07M
84.047 UPWARD BOUND $679,235
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS (GEAR UP 4 LA) $547,357
10.164 Southwest Regional Food Business Center $534,585
47.083 Equipment: MRI: Track 1 An interdisciplinary approach to high-resolution sea and lakefloor mapping through acquisition of an R2Sonic 2024 multibeam sonar $461,006
47.083 Equipment: MRI: Track 1 Acquisition of a benchtop microCT scanner for interdisciplinary undergraduate research and education $302,717
47.076 Creating Opportunities for High-achieving Students in Science and Mathematics through Scholarships, research experiences, Leadership, and Community $284,758
84.033 FEDERAL WORK-STUDY PROGRAM $283,414
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $215,071
97.036 US Department of Homeland Security - Federal Emergency Management Award $193,788
47.076 Center for Undergraduate Research in Mathematics $156,167
93.859 Regiodivergent Palladium-Catalyzed Decarboxylative Coupling of Stabilized Benzylic Nucleophiles $143,390
47.050 RUI: Collaborative Research: Understanding bioerosion from individuals to ecosystems: the impacts of biotic and abiotic stressors on sponge erosion of oyster reefs $123,683
93.855 Macrophage Second-line Responses to Group A Streptococcus Infection $112,908
10.170 California Department of Food and Agriculture $98,200
93.RD Alliance for Community Engagement-Climate and Health (ACE-CH) $83,534
93.243 Oxy Suicide Prevention Program $75,535
47.049 RUI-CHE: DEVELOPMENT OF ORGANOMETALLIC COMPLEXES FOR THE NEXT-GENERATION OF NON-AQUEOUS REDOX FLOW BATTERIES $65,490
47.075 Collaborative Research: SBP: Increasing Social Equality in STEM through Children's Structural Reasoning $65,364
47.050 Collaborative Research: Redefining the footprint of deep ocean methane seepage for benthic ecosystems $63,203
47.049 NSF Center for Computer-Assisted Synthesis $58,218
93.113 Reframing personal and community report back of consumer products by centering intersectionality $56,779
11.417 A half-century of ichthyoplankton: How studying larval fish can improve food security in our urban ocean $56,486
15.423 Environmental status of artificial structures offshore California $49,541
47.074 Collaborative Research: RUI: Keystone Molecules and estuarine foodw ebs: chemical defense and a novel biosynthetic pathw ay in a common Mudflat Mullusc $49,209
93.859 Photocatalyzed & Enantioselective Umpolung C-C Bond Forming Reactions of Carbonyls $48,700
10.310 Los Angeles Urban Agriculture Internship Program $44,462
47.050 Collaborative Research: EAR-Climate: Investigating the past, present, and future of glaciated alpine landscapes using an integrated data-model approach $40,548
93.113 Health symptoms and risk perception of urban environmental justice communities after a hydrogen sulfide disaster $39,192
47.074 A century of change in North American birds $34,328
81.U01 NGEE-Tropics Phase 3 $33,305
47.074 RUI: Marine Vampire Microbiome Project (MVP) Blood-feeding marine invertebrates and their bacterial accomplices $32,559
47.050 Collaborative Research: RUI: EAR-Climate: Investigating the past, present, and future of glaciated alpine landscapes using an integrated data-model approach $30,770
93.113 Los Angeles Voices on Oil, Community, Environment and Salud (LAS VOCES) Study $29,872
11.463 Subtidal Reef Restoration (CA) - II $25,707
12.901 Building Bridges: 6th EU/US Workshop on Automorphic Forms and Related Topics $19,320
84.019 Fulbright-Hays Faculty Research Abroad $18,528
47.050 MRI: Acquisition of a Malvern Particle size analyzer for interdisciplinary research and undergraduate education and research training $16,643
93.859 Photocatalyzed & Enantioselective Umpolung C-Cbond $16,269
47.049 USA Sky Partners: Expanding Access to Authentic Research Experiences for Undergraduates $16,218
47.075 Collaborative Research: Social Perception of Groups $15,207
47.049 BUILDING BRIDGES: FIFTH EU/US SUMMER SCHOOL ON AUTOMORPHIC FORMS AND RELATED TOPICS $14,769
47.049 RUI: DEVELOPMENT OF DIANIONIC ENOLATES FOR THE STEREOSELECTIVE SYNTHESIS OF NATURAL AND UNNATURAL AMINO ACIDS $12,227
10.559 Upward Bound USDA '23 - '28 $11,882
47.050 Collaborative Research: Evaluating tectonic models for the w estern US Cordillera through the metamorphic history of the Pelona-Orocopia-Rand schists $5,100
47.049 NRAO Student Observing Support $4,730
20.701 The Impact of Work-From-Home on Job and Housing Location in the Bay Area $3,918
47.050 Collaborative Research: RUI: Leveraging isotopic compositions of igneous systems to resolve the geometry and distribution of subducted sediment in the southern U.S. Cordillera $2,470
12.U02 NAVFAC SW Marine Habitat Services $1,242