Finding 1176607 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-05
Audit: 390423
Organization: Allegheny College (PA)

AI Summary

  • Core Issue: The College failed to update student enrollment status within the required 60 days, with five out of 40 instances of noncompliance.
  • Impacted Requirements: This finding violates 34 CFR 685.309 and 34 CFR 690.83(b)(2), indicating a significant deficiency in internal controls over federal programs.
  • Recommended Follow-Up: Develop and document policies to ensure timely reporting of enrollment changes, with a monthly reporting schedule to meet compliance.

Finding Text

Finding 2025-001: Student Financial Assistance Cluster, Department of Education Programs Program Names: Student Financial Assistance Cluster, Department of Education Programs Assistance Listing Numbers: 84.007, 84.033, 84.038, 84.063 and 84.268. Criteria or Specific Requirement: 34 CFR 685.309 and 34 CFR 690.83(b)(2) require the institution to update its Enrollment Reporting roster file at a minimum of every 60 days. Once a change in enrollment status has been received, the institution must update its roster file 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 NSLDS website. Condition: The College did not update certain changes in student status within the 60-day required time frame in five instances out of the 40 enrollment changes tested. We investigated others that had withdrawn and identified a total of 22 students who were not notified in a timely manner. Cause: The exception noted was a result of the College not reporting enrollment changes in a timely manner after returning from winter break. Effect or Potential Effect: The College did not comply with the provisions of 34 CFR 685.309 and 24 CFR 690.83(b)(2), resulting in a significant deficiency in internal control over major programs for federal awards. Questioned Costs: None noted. Context: Five instances of noncompliance were identified in a sample of 40 students. Identification as a Repeat Finding, if applicable: This is not a repeat finding. Recommendation: We recommend that the College develop and document policies and procedures to ensure that all changes in student status are reported accurately, completely and in a timely manner. We also recommend that the College report changes in student status once per month to ensure compliance with the required 60-day time frame. View of Responsible Officials: Management concurs with this finding. See separate corrective action plan document.

Corrective Action Plan

Finding 2025-001 The College concurs with the audit finding that students who withdrew at the conclusion of the fall 2024 semester were not reported to the National Student Loan Data System (NSLDS) within the required 60-day reporting timeframe. This occurred as a result of two primary factors: (1) the enrollment reporting schedule with the National Student Clearinghouse was outdated, and (2) the 60-day reporting requirement was not clearly defined within Allegheny’s internal processes. Allegheny recognizes the importance of timely and accurate reporting of students’ enrollment status to NSLDS. Enrollment rosters and updated enrollment statuses are regularly reported to NSLDS to ensure that changes affecting loan repayment obligations and in-school deferment eligibility are accurately reflected within the Department of Education’s records. The College is committed to strengthening its procedures to ensure continued compliance with federal reporting requirements. The College will continue to adhere to NSLDS reporting processes and required timelines. Through enhanced collaboration among the Financial Aid, Registrar’s, and Provost’s Offices, Allegheny will fully align and formalize enrollment reporting procedures. The College will review, verify, and update reporting schedules to ensure accuracy and compliance with applicable requirements. Specifically, the College will annually review its enrollment reporting schedule with the National Student Clearinghouse to ensure that enrollment data is transmitted to the National Student Loan Data System (NSLDS) at least once every 60 calendar days, in accordance with federal reporting requirements. For students who notify the College of their intent to leave at the upcoming conclusion of a semester, the College will report the student as enrolled on the final enrollment report for that term and will then manually update the student's enrollment status to withdrawn within a few days of the report’s submission, rather than waiting for the next scheduled enrollment transmission, to ensure timely and accurate reporting. Allegheny College will implement quarterly review of processes established to ensure compliance. This proactive approach will ensure ongoing compliance with federal regulations. In addition, Allegheny College is developing a secondary review process for each enrollment report submission to identify students with recent or pending enrollment status changes. This review will serve as a quality control check to ensure that students whose enrollment status has changed since the prior reporting period are accurately identified and updated, thereby strengthening oversight and ensuring timely and compliant reporting to NSLDS.

Categories

Student Financial Aid Reporting Significant Deficiency Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1176603 2025-001
    Material Weakness Repeat
  • 1176604 2025-001
    Material Weakness Repeat
  • 1176605 2025-001
    Material Weakness Repeat
  • 1176606 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $6.33M
84.063 FEDERAL PELL GRANT PROGRAM $2.43M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $921,306
64.027 POST-9/11 VETERANS EDUCATIONAL ASSISTANCE $676,106
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $335,341
84.033 FEDERAL WORK-STUDY PROGRAM $289,119
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $239,541
94.013 AMERICORPS VOLUNTEERS IN SERVICE TO AMERICA 94.013 $98,674
11.008 NOAA MISSION-RELATED EDUCATION AWARDS $80,801
47.074 BIOLOGICAL SCIENCES $67,985
47.078 POLAR PROGRAMS $5,100