Finding 1175279 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-25
Audit: 389014
Organization: Hilbert College (NY)

AI Summary

  • Core Issue: The College has significant deficiencies in internal controls over compliance with NSLDS enrollment reporting, leading to inaccurate student enrollment data.
  • Impacted Requirements: Schools must verify and report enrollment statuses within specified timeframes (30 or 60 days) as per federal regulations.
  • Recommended Follow-Up: The College should update its policies and procedures to ensure timely and accurate reporting of enrollment status changes to comply with regulations.

Finding Text

2025–001 National Student Loan Database System (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853, P063P241853; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of enrollment status submissions, the following was noted:  4 students out of a sample of 23 students tested were reported with incorrect enrollment status effective dates at the campus level.  2 students out of a sample of 23 students tested were reported outside the 30- or 60-day window.  2 students out of a sample of 23 students tested were reported with incorrect enrollment effective dates at both the campus and program levels.  1 student out of a sample of 23 students tested were reported with incorrect enrollment effective date at the program level.  2 students out of a sample of 23 students tested were reported as a withdrawal status at both the campus and programs levels but was graduated per Institution’s record, and student status was never subsequently updated. Questioned costs: None. Cause: The College's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected in the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: No. Recommendation: The College should review its policies and procedures on reporting enrollment status changes to NSLDS to ensure that all status changes are being reported timely and accurately to be in compliance with regulations. Views of responsible officials: Please refer to the attached corrective action plan.

Corrective Action Plan

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on reviewing enrollment status changes to NSLDS to ensure that all status changes are being reported timely and accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the NSLDS. The Registration and Records Office will continue to work with NSCL and NSLDS on specific enrollment scenarios that require different submission update requirements. Name(s) of the contact person(s) responsible for corrective action: Katelyn Letizia, Interim Vice President Institutional Effectiveness and Academic Strategy. Planned completion date for corrective action plan: May 31, 2026

Categories

Student Financial Aid Reporting Significant Deficiency

Other Findings in this Audit

  • 1175275 2025-001
    Material Weakness Repeat
  • 1175276 2025-001
    Material Weakness Repeat
  • 1175277 2025-001
    Material Weakness Repeat
  • 1175278 2025-001
    Material Weakness Repeat
  • 1175280 2025-002
    Material Weakness Repeat
  • 1175281 2025-002
    Material Weakness Repeat
  • 1175282 2025-002
    Material Weakness Repeat
  • 1175283 2025-002
    Material Weakness Repeat
  • 1175284 2025-002
    Material Weakness Repeat
  • 1175285 2025-003
    Material Weakness Repeat
  • 1175286 2025-003
    Material Weakness Repeat
  • 1175287 2025-003
    Material Weakness Repeat
  • 1175288 2025-003
    Material Weakness Repeat
  • 1175289 2025-003
    Material Weakness Repeat
  • 1175290 2025-004
    Material Weakness Repeat
  • 1175291 2025-004
    Material Weakness Repeat
  • 1175292 2025-004
    Material Weakness Repeat
  • 1175293 2025-004
    Material Weakness Repeat
  • 1175294 2025-004
    Material Weakness Repeat
  • 1175295 2025-005
    Material Weakness Repeat
  • 1175296 2025-005
    Material Weakness Repeat
  • 1175297 2025-005
    Material Weakness Repeat
  • 1175298 2025-005
    Material Weakness Repeat
  • 1175299 2025-005
    Material Weakness Repeat
  • 1175300 2025-006
    Material Weakness Repeat
  • 1175301 2025-006
    Material Weakness Repeat
  • 1175302 2025-006
    Material Weakness Repeat
  • 1175303 2025-006
    Material Weakness Repeat
  • 1175304 2025-006
    Material Weakness Repeat
  • 1175305 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $7.57M
84.063 FEDERAL PELL GRANT PROGRAM $3.41M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $71,019
84.033 FEDERAL WORK-STUDY PROGRAM $67,144
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $22,266