Finding Text
Federal Program: Student Financial Aid Cluster Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters Federal Agency: Department of Education ALN Number: 84.063, 84.268, 84.033, 84.007 Criteria: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as that student’s campus-level enrollment status for all programs the student is enrolled in at that location, even if the student is not currently taking coursework that applies to a particular program. If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for that program, even if the student is still taking coursework applicable to other programs in which the student is enrolled. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report three students’ Campus-Level enrollment status change to NSLDS. Context: Out of the thirty one students tested, we noted three students whose status change at the Program-Level and Campus-Level was not timely reported to NSLDS. Questioned costs: None. Cause: The College did not have formally documented controls related to the process of enrollment reporting, which is required under Uniform Grant Guidance. Effect: Student status changes exceeded the 60-day period for student enrollment changes reported in roster files. Recommendation: We recommend the College review current processes and implement updated processes and controls for reporting to NSLDS, implementing procedures to ensure submissions are reported timely and accurately. In addition, we recommend the College review the reporting in the system to ensure it can pull accurate reports of student enrollment status. Grantee Comments: See corrective action plan.