Finding 1174743 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-20
Audit: 388309
Organization: Clarkson College (NE)

AI Summary

  • Core Issue: The College has a significant weakness in its internal controls, leading to inaccurate reporting of student enrollment statuses to NSLDS.
  • Impacted Requirements: Compliance with 34 CFR 682.610 is at risk, as the College failed to certify enrollment every 60 days and report accurate enrollment data.
  • Recommended Follow-Up: The College should enhance its reporting procedures to ensure timely and accurate updates to NSLDS, addressing the repeat finding from the previous year.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Material Weakness in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of whether they receive aid from the institution. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: Of the 33 students selected for testing, 12 students had errors in enrollment status; the institution's records did not match what was reported to NSLDS. We also noted one student tested did not have enrollment data certified at least every 60 days as required. Additionally, one student’s enrollment begin date per the institution’s records did not agree to NSLDS records. Questioned Costs: None Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are timely and accurate. Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should reflect the student's last date of attendance and academically-related activity. In addition, students’ enrollment status should be certified every 60 days and the program begin date should be the first day attended at the College. Effect or Potential Effect of Finding: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, see finding 2024-001. Recommendation: We recommend the College review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College completed its implementation of Anthology as a new student information system (SIS) in FY 25. Enrollment reports from the new SIS are used to update the National Student Clearinghouse and thus the NSLDS. The Registrar’s Office is working with our Anthology partner to determine issues with the enrollment dates and statuses. Moving forward, the Registrar’s Office will also do an internal audit of enrollment records between the National Student Clearinghouse, NSLDS, and our internal SIS. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented in the Spring semester of FY 2025.

Categories

Student Financial Aid Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1174736 2025-002
    Material Weakness Repeat
  • 1174737 2025-002
    Material Weakness Repeat
  • 1174738 2025-002
    Material Weakness Repeat
  • 1174739 2025-002
    Material Weakness Repeat
  • 1174740 2025-002
    Material Weakness Repeat
  • 1174741 2025-002
    Material Weakness Repeat
  • 1174742 2025-002
    Material Weakness Repeat
  • 1174744 2025-003
    Material Weakness Repeat
  • 1174745 2025-003
    Material Weakness Repeat
  • 1174746 2025-003
    Material Weakness Repeat
  • 1174747 2025-003
    Material Weakness Repeat
  • 1174748 2025-003
    Material Weakness Repeat
  • 1174749 2025-003
    Material Weakness Repeat
  • 1174750 2025-003
    Material Weakness Repeat
  • 1174751 2025-003
    Material Weakness Repeat
  • 1174752 2025-004
    Material Weakness Repeat
  • 1174753 2025-004
    Material Weakness Repeat
  • 1174754 2025-004
    Material Weakness Repeat
  • 1174755 2025-004
    Material Weakness Repeat
  • 1174756 2025-004
    Material Weakness Repeat
  • 1174757 2025-004
    Material Weakness Repeat
  • 1174758 2025-004
    Material Weakness Repeat
  • 1174759 2025-004
    Material Weakness Repeat
  • 1174760 2025-005
    Material Weakness Repeat
  • 1174761 2025-005
    Material Weakness Repeat
  • 1174762 2025-005
    Material Weakness Repeat
  • 1174763 2025-005
    Material Weakness Repeat
  • 1174764 2025-005
    Material Weakness Repeat
  • 1174765 2025-005
    Material Weakness Repeat
  • 1174766 2025-005
    Material Weakness Repeat
  • 1174767 2025-005
    Material Weakness Repeat
  • 1174768 2025-006
    Material Weakness Repeat
  • 1174769 2025-006
    Material Weakness Repeat
  • 1174770 2025-006
    Material Weakness Repeat
  • 1174771 2025-006
    Material Weakness Repeat
  • 1174772 2025-006
    Material Weakness Repeat
  • 1174773 2025-006
    Material Weakness Repeat
  • 1174774 2025-006
    Material Weakness Repeat
  • 1174775 2025-006
    Material Weakness Repeat
  • 1174776 2025-007
    Material Weakness Repeat
  • 1174777 2025-007
    Material Weakness Repeat
  • 1174778 2025-007
    Material Weakness Repeat
  • 1174779 2025-007
    Material Weakness Repeat
  • 1174780 2025-007
    Material Weakness Repeat
  • 1174781 2025-007
    Material Weakness Repeat
  • 1174782 2025-007
    Material Weakness Repeat
  • 1174783 2025-007
    Material Weakness Repeat
  • 1174784 2025-008
    Material Weakness Repeat
  • 1174785 2025-008
    Material Weakness Repeat
  • 1174786 2025-008
    Material Weakness Repeat
  • 1174787 2025-008
    Material Weakness Repeat
  • 1174788 2025-008
    Material Weakness Repeat
  • 1174789 2025-008
    Material Weakness Repeat
  • 1174790 2025-008
    Material Weakness Repeat
  • 1174791 2025-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $10.27M
84.063 FEDERAL PELL GRANT PROGRAM $1.43M
93.264 NURSE FACULTY LOAN PROGRAM (NFLP) $753,020
93.364 NURSING STUDENT LOANS $608,904
84.033 FEDERAL WORK-STUDY PROGRAM $42,196
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $33,497