Finding Text
Criteria or Specific Requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non- Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance: 1. The Code of Federal Regulations, 34 CFR 685.309(b) and the NSLDS Enrollment Reporting Guide, states that: Colleges must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The college is required to report changes in the students’ enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that college must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Colleges must have some arrangement to report student program enrollment effective date and status to NSLDS. 2. Per Section 4.4.8 of the NSLDS Enrollment Reporting Guide, the program begin date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program. Condition: During testing of the enrollment reporting, we identified the following errors: The change in status was not reported at the program level. The program begin date reported to NSLDS does not match the program begin date per the college’s records. Questioned costs: None Context: This condition occurred for the following: 1. The enrollment status was not reported for 3 out of 60 students. 2. The program begin date was incorrectly reported for 6 out of 60 students Cause: The college was having issues with archives not allowing the National Student Clearing house (NSC) reports to run out of colleague. The decision was made to do a mass purging of the archive file in 2023 to eliminate the issue. Months later it was realized that doing this affected the Program start date. This purging of the archives also caused transmission issues between the NSC and NSLDS which resulted in the student’s program status not being changed. Effect: Student enrollment status and program begin date was not reported accurately to NSLDS. Repeat Finding: No. Recommendation: The College should evaluate their procedures and policies related to reporting status changes and program begin dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.