Finding 1190768 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-27
Audit: 395071
Organization: East Central University (OK)

AI Summary

  • Core Issue: Enrollment changes for federal aid recipients were not reported to NSLDS accurately or on time.
  • Impacted Requirements: Compliance with 34 CFR 690.83(b)(2) and 34 CFR 685.309 regarding NSLDS reporting.
  • Recommended Follow-Up: The University needs to enhance controls to ensure timely and accurate enrollment reporting to NSLDS.

Finding Text

Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024 - 2025 Criteria or Specific Requirement - Special Tests: NSLDS Reporting 34 CFR 690.83(b)(2) and 34 CFR 685.309 Condition - Enrollment changes were not reported to the National Student Loan Data System (NSLDS) on a timely and accurate basis. Cause - The University did not appropriately report changes in enrollment status to NSLDS. Effect or Potential Effect - NSLDS was not notified of student enrollment status changes for Direct Loan and Pell Grant recipients in a timely or accurate manner. Questioned Costs - None Context - Out of a population of 2,707 student enrollment status changes requiring reporting to NSLDS, a sample of 25 students with status changes were selected for testing. Our sample was not, and was not intended to be statistically valid. The program enrollment effective date reported to NSLDS did not agree to the student information system, Colleague, for three students tested. For two students tested, the incorrect enrollment status was reported to NSLDS. Identification as a Repeat Finding - Repeat finding, 2024-006 Recommendation - The University should review and update controls in place to ensure accurate and timely enrollment reporting to NSLDS.

Corrective Action Plan

The East Central University Records Office reports enrollment to the National Student Clearinghouse (NSC). The NSC then transmits that data to the National Student Loan Data System (NSLDS) where it becomes part of the financial aid record. The graduate student enrollment status issue was addressed in March 2025 as a result of the 2024-year audit. Importantly, because that correction was made in March of 2025, it was expected that the 2025-year audit identified Spring 2025 semester students prior to when the correction was made. The Records Office is confident this particular issue was fully resolved in March 2025 in accordance with the action plan put forward at the time. With regard to the student's status effective date differing between NSLDS and Colleague, considerable time has been devoted to investigating this case. This includes a one-hour consultation with Strata information Group (SIG) on 3/6/2026. However, ECU is not able to determine where the date reported to NSLDS came from. Much review of the Colleague to NSC reporting procedures has taken place since Fall 2024, which gives the Records Office confidence that whatever the cause of this data discrepancy, it is unlikely to represent a current systemic problem. However, the Records Office will add to the list of preliminary data checks (i.e. , prior to submitting the Colleague file to NSC), to randomly select students who have a within-term change of status and verify that the date in the NSC file matches what we expect to see in Colleague. With regard to Spring graduated status effective dates exceeding the end of the term, while working with the SIG consultant to review procedures for NSC reporting, it was noticed that Colleague requires NSC reporting period dates to not exceed the end of term. This caused the Records Office to raise the question of the award date. ECU was able to determine that NSC does expect the last day of term and the award date to match. Campus stakeholders were notified that the historic practice was ending. Beginning with Fall 2025, the award date and end of term match. While the Records Office is confident much progress has been made, minor findings through 2026 are possible.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1190767 2025-002
    Material Weakness Repeat
  • 1190769 2025-003
    Material Weakness Repeat
  • 1190770 2025-003
    Material Weakness Repeat
  • 1190771 2025-004
    Material Weakness Repeat
  • 1190772 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $11.57M
84.063 FEDERAL PELL GRANT PROGRAM $9.46M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $5.56M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $516,184
84.066 TRIO EDUCATIONAL OPPORTUNITY CENTERS $461,616
84.382 STRENGTHENING MINORITY-SERVING INSTITUTIONS $410,297
84.042 TRIO STUDENT SUPPORT SERVICES $391,438
84.033 FEDERAL WORK-STUDY PROGRAM $355,065
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $333,775
84.428 AUGUSTUS F. HAWKINS CENTERS OF EXCELLENCE—TEACHER PREPARATION AND DEVELOPMENT $311,930
93.778 MEDICAL ASSISTANCE PROGRAM $304,321
84.031 HIGHER EDUCATION INSTITUTIONAL AID $295,632
84.047 TRIO UPWARD BOUND $284,848
97.067 HOMELAND SECURITY GRANT PROGRAM $280,976
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $196,215
16.526 OVW TECHNICAL ASSISTANCE INITIATIVE $185,487
93.788 OPIOID STR $112,331
66.445 INNOVATIVE WATER INFRASTRUCTURE WORKFORCE DEVELOPMENT PROGRAM (SDWA 1459E) $108,745
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $84,945
66.509 SCIENCE TO ACHIEVE RESULTS (STAR) RESEARCH PROGRAM $80,169
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $68,000
84.335 CHILD CARE ACCESS MEANS PARENTS IN SCHOOL $64,987
15.554 COOPERATIVE WATERSHED MANAGEMENT $59,517
47.050 GEOSCIENCES $53,546
93.799 CARA ACT – COMPREHENSIVE ADDICTION AND RECOVERY ACT OF 2016 $50,347
66.312 ENVIRONMENTAL JUSTICE GOVERNMENT-TO-GOVERNMENT (EJG2G) PROGRAM $38,382
15.156 TRIBAL CLIMATE RESILIENCE $37,283
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $36,505
47.041 ENGINEERING $32,479
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $27,101
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $16,915
66.604 ENVIRONMENTAL JUSTICE SMALL GRANT PROGRAM $14,230
93.632 UNIVERSITY CENTERS FOR EXCELLENCE IN DEVELOPMENTAL DISABILITIES EDUCATION, RESEARCH, AND SERVICE $9,918
66.511 OFFICE OF RESEARCH AND DEVELOPMENT CONSOLIDATED RESEARCH/TRAINING/FELLOWSHIPS $7,993
15.611 WILDLIFE RESTORATION AND BASIC HUNTER EDUCATION AND SAFETY $7,970
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $6,994
45.312 NATIONAL LEADERSHIP GRANTS $2,400