Finding Text
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program, and 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: During testing of 40 enrollment changes, we identified 5 instances of changes being reported after 60 day threshold, 33 instances where the enrollment batch wasn't certified within 60 days, and 1 instance of incorrect enrollment status. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure that all reporting compliance was filed timely. Cause: The College’s processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS. Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes, 2024-003 Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding. The College utilizes a third-party, National Student Clearinghouse (NSC) to report to the National Student Loan Data System (NSLDS). Clarification was obtained from NSC regarding the process between NSC and NSLDS to prevent future occurrences. The NSC report will be submitted at the earliest possible date to provide additional time to review and verify that accurate data was transferred from NSC to NSLDS.