Finding 1174887 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-23
Audit: 388459
Organization: Westminster College (PA)

AI Summary

  • Core Issue: The College did not report enrollment status changes for 3 out of 60 students within the required timeframe, violating 34 CFR 668.32.
  • Impacted Requirements: Timely and accurate enrollment reporting is essential for determining student eligibility for benefits and managing federal loan programs.
  • Recommended Follow-Up: Implement a review process for enrollment submissions and develop clear policies to ensure all changes are reported accurately and on time.

Finding Text

This section identifies the audit findings required to be reported by 2 CFR 200.516(a) (significant deficiencies, material weaknesses, material instances of noncompliance, including questioned costs and material abuse.) Finding 2025-001: Student Financial Assistance Cluster, Department of Education Programs Program Names: Federal Direct Student Loans Assistance Listing Numbers: 84.268 Criteria or Specific Requirement: 34 CFR section 685.309 states that once a change in student enrollment status has been received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Family Education Loan Program (FFEL) loan holders by the Department of Education (ED). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. 34 CFR 668.32 requires that an organization report student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse within the required timeframe as required under 34 CFR 668.32 for 3 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College’s processes and controls surrounding review of exchange students’ and high school students’ reporting information. The College did not include all student enrollment changes in the clearinghouse timely. Effect or Potential Effect: A student’s enrollment status determines eligibility for in-school status, deferment and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is not a repeat finding. Recommendation: We recommend the College implement a review over the exchange students’ and high school students’ enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.

Corrective Action Plan

The College’s Vice President for Academic Affairs and Dean of the College concurred with the finding identified. The College has revised its policies and procedures as follows: Historically, Student Affairs coded only those students who took a Leave of Absence during the semester (“L”) or withdrew during the semester (“W”). Student Affairs has created a new code (“N”) to track students who inform the college of their intent to withdraw at the end of a given semester. At the end of each semester, Student Affairs provides the Registrar’s Office with a report of all students who informed the college of their intent to unenroll (“L”, “W”, and “N”). Using the report, the Registrar’s Office confirms that all students have been accurately exited with the appropriate exit date and exit reason prior to submitting the final “end of term” report to the National Student Clearinghouse. This new process was implemented beginning in the Fall 2025 semester. The corrective actions will be implemented by Dr. Kristen M. Amick, Registrar. Dr. Amick’s email address is: amickkm@westminster.edu.

Categories

Student Financial Aid Eligibility Material Weakness Reporting Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $6.62M
84.063 FEDERAL PELL GRANT PROGRAM $2.13M
84.042A TRIO STUDENT SUPPORT SERVICES $297,747
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $294,209
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $110,002
84.033 FEDERAL WORK-STUDY PROGRAM $97,451