Finding 1186709 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-26
Audit: 394416
Organization: College Unbound (RI)

AI Summary

  • Core Issue: The College failed to report student enrollment changes to the NSLDS on time, with delays of up to 72 days and incorrect status updates.
  • Impacted Requirements: Compliance with 34 CFR 685.309(b)(2) and 2 CFR Part 200, Appendix XI, which mandate timely and accurate reporting of enrollment changes.
  • Recommended Follow-Up: Strengthen internal controls to ensure compliance with federal reporting requirements and prevent future errors.

Finding Text

Finding number: 2025-003 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2025 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 4 out of 14 students were reported late to the NSLDS by 72 days, 3 out of 14 students reported an incorrect effective date to the NSLDS, and 3 out of 14 students had a status change reported incorrectly as withdrawn instead of graduated. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2024-004 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Finding number: 2025-003 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2025 Corrective Action Plan: College Unbound is expanding capacity, hiring in both the Financial Aid and Accounting departments. We are also hiring a new CFO in the Summer of 2026. With this increased capacity, we will have backups for each process and institute a series of double checks in order to ensure accuracy. Timeline for Implementation of Corrective Action Plan: August 15, 2026 Contact Person: Mark Hartonchik, Interim CFO

Categories

No categories assigned yet.

Other Findings in this Audit

  • 1186708 2025-004
    Material Weakness Repeat
  • 1186710 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $3.28M
84.063 FEDERAL PELL GRANT PROGRAM $2.47M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $549,987
84.428 AUGUSTUS F. HAWKINS CENTERS OF EXCELLENCE—TEACHER PREPARATION AND DEVELOPMENT $315,970
84.425 EDUCATION STABILIZATION FUND $276,960
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $38,620
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $26,262
84.033 FEDERAL WORK-STUDY PROGRAM $24,762