Finding Text
Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 690.83(b)(2) and 2 CFR 685.309 requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been 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. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: It was identified that the College did not have effective internal controls to ensure all graduate data was submitted to National Student Loan Data System (NSLDS) on a timely basis. During the audit over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 60 selected whose enrollment change dates were not timely reported to the NSLDS. For three selections, the students were a part of the College’s 3+1 program which required graduate dates to be manually updated in NSLDS. The College set reminders to update the data manually, however, those reminders were set at 61 days instead of the required 60 days. These three enrollment changes were accurately reported to NSLDS. For two selections, these students were May 2025 graduates that were reported to NSLDS with other May 2025 graduates on a timely basis but due to system errors with information transferred, were marked at “W” within the NSLDS system. Once identified in error during the audit, the information for these two students was updated within NSLDS in October 2025 by the College. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not ensure reminders on manually updated graduate information were set to ensure timely reporting to NSLDS. Further, error reports were not reviewed and a final reconciliation was not performed to ensure all graduates were accurately reported within NSLDS. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 690.83(b)(2) and 2 CFR 685.309. View of Responsible Officials: We concur with the finding and are in the process of improving controls over reviewing the error reports and remin