Finding Text
U.S. Department of Education 2025-005: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: Enrollment status changes were either not reported to NSLDS within 60 days 2025 – 005: Special Tests and Provisions – NSLDS Enrollment & Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P233052, P063P243052, P268K243052, P268K253052 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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). 2025 – 005: Special Tests and Provisions – NSLDS Enrollment & Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P233052, P063P243052, P268K243052, P268K253052 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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 – The Code of Federal Regulations, 34 CFR 685.309(b), states that: Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the 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 institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Condition: Enrollment status changes were either not reported to NSLDS within 60 days or did not match the College’s records for a portion of the sampled students. Questioned Costs: None Context: In our statistically valid sample of 60 students, we found 16 cases where enrollment status changes were not reported to NSLDS within 60 days, and 4 cases where the students’ status changes did not match between the College’s records and NSLDS. Cause: The College's internal controls did not identify the errors in compliance with the criteria mentioned above. Effect: Student enrollment status was not reported accurately and/or timely to NSLDS. Repeat Finding: Yes Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective 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.