Finding 1179653 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-16
Audit: 392056
Organization: Rogue Community College (OR)
Auditor: EIDE BAILLY LLP

AI Summary

  • Core Issue: The College has a significant deficiency in internal controls regarding the accurate reporting of student enrollment statuses to NSLDS.
  • Impacted Requirements: Institutions must report enrollment status changes within 60 days, as mandated by federal regulations.
  • Recommended Follow-Up: The College should reassess its processes following the new ERP system implementation to ensure accurate NSLDS reporting.

Finding Text

U.S. Department of Education Student Financial Assistance Cluster Federal Financial Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirements: Special Tests & Provisions – NSLDS Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: Under 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. Condition: During our testing over enrollment reporting, it was noted 4 of the 60 students tested did not have accurate information reported to NSLDS. Cause: During the current year, the College implemented a new ERP system. As a result, data conversion issues between the new system and NSLDS reporting led to inaccurate enrollment information being reported. Effect: The students’ enrollment status was not accurately reported in NSLDS. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 participants out of 660 students who had a change in enrollment status were selected for testing. Repeat Finding from the Prior Year(s): Yes, see finding 2024-002 Recommendation: With the new system, the College needs to review the current process to ensure enrollment status is accurately reported to NSLDS. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. The support provided by RCC for the students’ last date of attendance did not agree to the students’ withdrawal that had been submitted to NSLDS. Responsible Individuals: Danielle Crouch, Registrar and Analisa Gifford, Assistant Registrar Corrective Action Plan: During the 2023-2024 academic year, we were utilizing an outdated, homegrown Student Information System (SIS). A previously unidentified flaw in the system’s programming logic caused incorrect withdrawal dates to be populated in the National Student Clearinghouse (NSC) report. For the 2024-2025 academic year, we have transitioned to Jenzabar One, an industry-recognized SIS that includes built-in Enrollment Reporting functionality. To ensure accurate reporting moving forward, we are conducting audits of withdrawal dates at the end of each term. With the implementation of this new system and enhanced audit processes, this issue will be fully mitigated. Rogue Community College has implemented corrective actions to strengthen internal controls and ensure the accurate reporting of student enrollment statuses to the National Student Loan Data System (NSLDS). The College now utilizes withdrawal reports to systematically identify students who have withdrawn from all enrolled courses. These reports are reviewed to verify each student’s official withdrawal date prior to submission to NSLDS. For students who receive non-passing grades, the College reviews and reports the last date of attendance, when applicable, to ensure accurate determination of the student’s withdrawal date. As additional internal control, the College conducts term-end audits of withdrawal dates and last dates of attendance to confirm that enrollment status changes have been reported accurately and in accordance with federal requirements. Any discrepancies identified through this review process are corrected promptly. Additionally, the College utilizes graduation reports to verify that students who have completed all program requirements within their declared major are appropriately reported to NSLDS with an enrollment status of Graduated. Through these enhanced monitoring and verification procedures, Rogue Community College is confident that enrollment status changes are reported accurately and in compliance with the requirements outlined in 34 CFR 690.83(b)(2) and 34 CFR 685.309. Anticipated Completion Date: October 2025

Categories

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

Other Findings in this Audit

  • 1179650 2025-001
    Material Weakness Repeat
  • 1179651 2025-001
    Material Weakness Repeat
  • 1179652 2025-001
    Material Weakness Repeat
  • 1179654 2025-002
    Material Weakness Repeat
  • 1179655 2025-002
    Material Weakness Repeat
  • 1179656 2025-002
    Material Weakness Repeat
  • 1179657 2025-002
    Material Weakness Repeat
  • 1179658 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $11.26M
84.268 FEDERAL DIRECT STUDENT LOANS $4.13M
93.493 CONGRESSIONAL DIRECTIVES $3.55M
84.044 TRIO TALENT SEARCH $599,930
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $580,265
84.042 TRIO STUDENT SUPPORT SERVICES $511,701
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $503,814
84.066 TRIO EDUCATIONAL OPPORTUNITY CENTERS $291,976
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $212,900
84.033 FEDERAL WORK-STUDY PROGRAM $175,751
84.425 EDUCATION STABILIZATION FUND $82,848
17.261 WORKFORCE DATA QUALITY INITIATIVE (WDQI) $63,375
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $20,000
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $4,886
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $3,833