Finding 1175636 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-26

AI Summary

  • Core Issue: 24 out of 60 students had incorrect withdrawal dates reported to NSLDS due to a coding error in the student information system.
  • Impacted Requirements: Institutions must accurately report enrollment and withdrawal information to NSLDS within 60 days to comply with OMB guidelines.
  • Recommended Follow-Up: Implement controls and system improvements to ensure accurate reporting of effective dates for enrollment status changes.

Finding Text

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions 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 which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Furthermore, when a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Material Weakness in Internal Control over Compliance – We identified that 24 students of 60 tested had incorrect effective withdrawal dates reported to NSLDS. These dates were incorrectly reporting the student’s enrollment date to NSLDS, rather than their actual withdrawal date, due to a coding error in the District’s student information system. Additionally, we noted one student who received a Direct Loan whose withdrawal status was not certified in NSLDS within the required 60-day period following their withdrawal, due to this coding error. Questioned Costs None noted. Context We tested a non-statistical sample of 60 student status changes of more than 250 identified during the 2025 fiscal year. Effect Failure to report accurate and timely withdrawal information to NSLDS can result in: Improper loan servicing timelines, Incorrect calculation of grace periods and repayment start dates, Potential noncompliance with Title IV program requirements, and Risk of financial exposure to the institution and borrowers. Repeat Finding (Yes or No) No. Cause The condition resulted from a system configuration error in the District’s student information system. Specifically, the system was defaulting the withdrawal effective date to the student’s enrollment date, regardless of the actual withdrawal or last date of academic activity. This error went undetected during the reporting process. Recommendation The District should implement controls to ensure effective dates of enrollment status changes are accurately captured and reported to NSLDS. Because this is a partially automated process through the District’s information systems, we recommend implementation of system improvements to ensure that the correct effective date, rather than the process or run date, is reported.

Corrective Action Plan

The District has identified the issue and confirmed that enrollment records are now populating with the correct withdrawal dates. Moving forward, we will collaborate with Financial Aid and IT to implement a validation process. As part of this process, a sample of 20 students will be tested each reporting cycle to verify that dates reported to the National Student Clearinghouse (NSC) are accurately reflected in the National Student Loan Data System (NSLDS). To ensure continued compliance, the District will establish a new Enrollment Reporting Workgroup that will meet once per semester, following the submission of the second NSC report. This workgroup will review results of the sample testing, monitor reporting accuracy, and address any discrepancies promptly.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1175633 2025-002
    Material Weakness Repeat
  • 1175634 2025-002
    Material Weakness Repeat
  • 1175635 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $13.12M
84.268 FEDERAL DIRECT STUDENT LOANS $4.33M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $635,784
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $482,304
84.033 FEDERAL WORK-STUDY PROGRAM $302,360
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $223,417
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $189,731
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $42,214
93.658 FOSTER CARE TITLE IV-E $34,054
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $32,541
10.558 CHILD AND ADULT CARE FOOD PROGRAM $18,408
12.006 NATIONAL DEFENSE EDUCATION PROGRAM $8