Finding 1175253 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-25
Audit: 388965
Auditor: EIDE BAILLY LLP

AI Summary

  • Core Issue: The College failed to report changes in student enrollment status accurately or within the required 60-day timeframe.
  • Impacted Requirements: Compliance with 34 CFR 690.83(b)(2) and 34 CFR 685.309 regarding timely enrollment reporting.
  • Recommended Follow-Up: The Enrollment Services Office should enhance practices and controls to ensure accurate and timely reporting to NSLDS.

Finding Text

2025-001 U.S. Department of Education Student Financial Assistance Cluster Federal Financial Assistance Listing Number(s): 84.007, 84.033, 84.063, 84.268 Compliance Requirement(s): Special Tests and Provisions – Enrollment Reporting Material Weakness in Internal Control Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. Condition: During our testing of compliance for Enrollment Reporting, there were 9 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student’s change in enrollment status. Cause: Enrollment Services did not catch that some status changes that had been reported to the Federal Clearing House did not get updated in NSLDS by the Federal Clearing House. In addition, Enrollment Services did not include Winterim sources in calculating a student’s spring semester enrollment status. Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 participants out of 849 students who had a change in enrollment status were selected for testing. Repeat Finding from Prior Year(s): Yes Recommendation: The Enrollment Services Office should review their current practices and controls over reporting changes in student enrollment statuses to ensure any change to a student’s enrollment status is reported both accurately and timely to NSLDS. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Material Weakness in Internal Control Finding Summary: During testing of compliance for Enrollment Reporting, there were 9 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student’s change in enrollment status. Responsible Individuals: Karla Winter, Registrar and Randy Mashek, Financial Aid Director Corrective Action Plan: The Registrar’s Office will collaborate with the Financial Aid Office to provide oversight to the Enrollment Reporting process. Oversight includes timely batch reporting of student enrollment statuses to the National Student Clearinghouse (NSC) for all periods of enrollment, NSC Error Report review and resolution between NICC’s internal Student Information System (Colleague) with the National Student Loan Data System (NSLDS), as well as having documented policies and procedures in place in order to administer, implement and comply with the full scope of Enrollment Reporting on an ongoing basis. The Policies and Procedures will address the previously recommended requirement of the Registrar’s Office to conduct and retain evidence of quality sampling once a semester. Implementation of certain measures has already begun in 2025-26 with the following steps: 1. The Registrar implemented a new reporting schedule with NSC to capture the Winterim semester (which is part of the spring financial aid semester) to accurately reflect the enrollment from that special mini session. This was implemented for the Winterim 2025 session (December 2025-January 2026) and reporting began 1/9/2026. 2. The Financial Aid Office is implementing a new system to review and resolve NSC Error Reports (NSLDS SSCR) beginning with the spring 2026 semester. These reports are provided by the Registrar, and produced by NSC after each enrollment submission. The Financial Aid staff will review Colleague and NSLDS records in order to determine corrective action in the required timeframe and then provide enrollment changes to NSC to have the student’s NSLDS record updated with accurate information. 3. NSC will update NICC’s reporting codes from the current two branches (00 Calmar and 01 Peosta) to a single reporting branch (00) beginning with the fall 2026 semester (2026-27 academic year). This change will align with recent updates over the past few years from two individual school codes (Calmar and Peosta) to just one code with several Federal Student Aid (FSA) systems. These systems include Student Loan origination at the Common Origination & Disbursement Web Site (COD), FSA Partner Connect as well as the Free Application for Federal Student Aid (FAFSA) school codes. The decision to transition from two codes to one in many reporting areas was made in order to reduce student confusion between campuses when completing the FAFSA, reduce reporting inefficiencies and errors, as well as streamline multiple reporting challenges for federal and state aid reporting. The actual process presented many challenges for NICC and FSA and was implemented over the past two years successfully. However, the transition did not include the enrollment reporting side with NSC/NSLDS which has been the source of many of our multiple student record errors. Anticipated Completion Date: Ongoing. Fully functional with the start of 2026-27 year.

Categories

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

Other Findings in this Audit

  • 1175248 2025-001
    Material Weakness Repeat
  • 1175249 2025-001
    Material Weakness Repeat
  • 1175250 2025-001
    Material Weakness Repeat
  • 1175251 2025-001
    Material Weakness Repeat
  • 1175252 2025-001
    Material Weakness Repeat
  • 1175254 2025-002
    Material Weakness Repeat
  • 1175255 2025-002
    Material Weakness Repeat
  • 1175256 2025-002
    Material Weakness Repeat
  • 1175257 2025-002
    Material Weakness Repeat
  • 1175258 2025-002
    Material Weakness Repeat
  • 1175259 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $4.87M
84.268 FEDERAL DIRECT STUDENT LOANS $1.80M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $336,183
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $321,271
84.042 TRIO STUDENT SUPPORT SERVICES $312,447
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $302,685
93.493 CONGRESSIONAL DIRECTIVES $129,946
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $121,600
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $92,143
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $89,335
17.259 WIOA YOUTH ACTIVITIES $76,365
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $63,936
64.027 POST-9/11 VETERANS EDUCATIONAL ASSISTANCE $37,395
84.033 FEDERAL WORK-STUDY PROGRAM $33,043
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $25,384
10.902 SOIL AND WATER CONSERVATION $19,671
10.558 CHILD AND ADULT CARE FOOD PROGRAM $19,560
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $19,338
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $582