Finding 1181980 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-23
Audit: 393337
Auditor: WIPFLI LLP

AI Summary

  • Core Issue: Inaccurate and late reporting of enrollment status changes to NSLDS for 3 out of 17 student files.
  • Impacted Requirements: Federal regulations require timely reporting of enrollment changes within 30 or 60 days, depending on reporting methods.
  • Recommended Follow-Up: Strengthen internal controls, conduct periodic checks, verify accuracy before certification, and ensure compliance with reporting timelines.

Finding Text

Finding 2025-001 Special Tests & Provisions – NSLDS Reporting Federal Program Information: Funding agency: US Department of Education Title: Student Financial Aid Cluster ALN: 84.007, 84.033, 84.063, 84.268 Criteria: Federal regulations (34 CFR 685.309 and NSLDS Enrollment Reporting guidance) require institutions to report enrollment status changes to National Student Loan Data System (NSLDS) accurately and timely. Enrollment status changes must generally be reported within 30 days of the status change if the institution does not file roster reports, or within 60 days of the date the institution becomes aware of the status change when following normal roster reporting cycles. Condition: During our examination of 17 student files with enrollment status changes, we noted 3 students whose enrollment statuses were either inaccurately reported to NSLDS or reported outside of the required timeframe. Student A - Institutional records show an LDA of 10/9/24; NSLDS reflects a withdrawal effective date of 12/6/24. Student B – Withdrawal not reported within the required 60 day timeframe. The student withdrew on 5/9/25; the date of determination (DOD) was 5/14/25; NSLDS certification occurred on 9/4/25. Student C – Withdrawal not reported within the required 60 day timeframe. The student withdrew on 5/9/25; the date of determination (DOD) was 5/14/25; NSLDS certification occurred on 9/4/25. Context: The College processes enrollment data for a substantial number of Title IV-eligible students. Of the 17 students selected for testing, 3 (18%) had inaccurate or incomplete NSLDS reporting. Errors were not concentrated in a single academic program or term, indicating that the issue may be broader within the enrollment reporting process. These inconsistencies increase risk because NSLDS relies on accurate enrollment data to determine in-school status, grace periods, and repayment dates. Questioned Costs: $0 Effect: NSLDS did not accurately reflect the students’ enrollment status changes. Inaccurate or late reporting may result in: incorrect repayment notifications, improper deferment or grace period calculations, and potential noncompliance with federal reporting requirements. Cause: The College reported the last day of the term rather than the student’s actual last date of attendance, resulting in inaccurate effective dates being transmitted to NSLDS. The College did not submit the enrollment status updates within the required 60‑day reporting window. Repeat: Yes - Years as Repeat Finding: One Auditor’s Recommendation: The College should implement stronger internal controls over NSLDS enrollment reporting, including: periodic spot checks comparing NSLDS reflected statuses and effective dates to institutional records; verification of LDA/DOD accuracy prior to certification; and monitoring compliance with the 60 day reporting requirement to ensure enrollment changes are transmitted timely. Management should consider incorporating a secondary review process. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan.

Corrective Action Plan

Condition: The audit identified instances in which enrollment status changes for withdrawn students were not reported to the National Student Loan Data System (NSLDS) within the required 60-day timeframe and in some cases the withdrawal date reported did not reflect the student’s actual Last Date of Attendance (LDA). Cause: The discrepancies occurred because the academic term end date was used instead of the student’s actual Last Date of Attendance for certain withdrawn students. In addition, in limited cases enrollment status changes for students who did not return for a subsequent term were not reported within the required 60-day window due to the timing of non-returning student reporting cycles. Corrective Action Plan: Sauk Valley Community College will implement revised procedures and additional monitoring controls to ensure that enrollment reporting to NSLDS complies with federal requirements. The College submits enrollment reporting through the National Student Clearinghouse, which transmits enrollment data to NSLDS on the College’s behalf. The College utilizes an internal system to generate enrollment reporting files based on institutional enrollment and withdrawal data. The Registrar reviews the file prior to transmission to the National Student Clearinghouse for submission to NSLDS. Enrollment reporting is currently submitted on a monthly basis. To address the reporting discrepancies identified in the audit, the College will implement the following corrective actions: 1. Accurate Withdrawal Date Reporting Procedures will be updated to ensure that the effective withdrawal date reported to NSLDS reflects the student’s actual Last Date of Attendance (LDA) recorded in institutional records rather than the academic term end date or administrative processing date. 2. Monthly Reconciliation Process The Registrar and Financial Aid Office will perform a monthly reconciliation of institutional withdrawal records to NSLDS enrollment reporting data to confirm that enrollment status changes and withdrawal dates have been reported accurately and within the required reporting timeframe. 3. Monitoring of Potential Unofficial Withdrawals Students who receive all “F” or “W” grades will be reviewed as potential unofficial withdrawals to ensure that the correct Last Date of Attendance is identified and reported when applicable. 4. Monitoring of Non-Returning Students Students who do not return for the summer or fall term following the spring semester will be reviewed by the end of June to determine whether a withdrawal status must be reported to NSLDS. The College will follow the National Student Clearinghouse guidance regarding non-required term enrollment reporting to support accurate status reporting. 5. Ongoing Compliance Oversight Financial Aid and the Registrar will work collaboratively to review enrollment reporting data on an ongoing basis to ensure compliance with federal reporting requirements, including the 60-day reporting requirement for enrollment status changes. 6. Staff Training and Procedural Reinforcement The Registrar and the Financial Aid Office will review NSLDS enrollment reporting guidance and applicable federal requirements with relevant staff to reinforce proper reporting procedures and ensure consistent understanding of withdrawal date reporting requirements and timelines. These procedures will provide additional oversight to ensure that withdrawal dates are reported accurately and that enrollment status changes are transmitted to NSLDS within the required timeframe. Responsible Officials: Jennifer Schultz, Dean of Student Services, Lizzie Harper, Director of Financial Assistance, and Meagan Rivera, Registrar Planned Implementation Date: The revised procedures will be implemented immediately, beginning with the current enrollment reporting cycle, and will continue as an ongoing compliance control.

Categories

Student Financial Aid Reporting Special Tests & Provisions Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $2.93M
84.268 FEDERAL DIRECT STUDENT LOANS $553,074
84.042 TRIO_STUDENT SUPPORT SERVICES $291,198
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $214,204
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $175,911
84.033 FEDERAL WORK-STUDY PROGRAM $162,881
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $118,988
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $98,301
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $89,857
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $85,027