Finding Text
2025 – 004: Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: 84.063, 84.268 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During testing of NSLDS enrollment reporting, we identified multiple instances of noncompliance related to timely and accurate enrollment reporting and certification. Specifically, the following issues were noted: 1. Enrollment date discrepancies The enrollment date per campus level institutional records does not match the enrollment date per NSLDS. 2. Program start date discrepancies The program start date per institutional records does not match program start date per NSLDS. 3. Untimely reporting of enrollment status changes The enrollment status change was not timely reported to NSLDS. 4. Missed enrollment certification One student was not certified within the required 60‑day period. 5. Enrollment status discrepancies The enrollment status change per institutional records does not match the status per NSLDS. Section III –Findings and Questions Costs – Major Federal Programs (Continued) 2025 – 004: Enrollment Reporting (Continued) 6. Inaccurate institutional records Institutional records did not accurately reflect the student’s enrollment status, despite NSLDS and email communication reflecting the withdrawal. Questioned costs: None Context: 1. This condition occurred in 4 out of 26 students tested. 2. This condition occurred in 9 out of 26 students tested. 3. This condition occurred in 2 out of 26 students tested. 4-6 This condition occurred in 1 out of 26 students tested. Cause: The University did not have sufficient controls in place to ensure enrollment information submitted to NSLDS was complete, accurate, and reviewed for consistency with institutional records, nor adequate monitoring procedures to ensure enrollment status changes and required certifications were submitted timely. Effect: Failure to accurately and timely report enrollment information to NSLDS may result in inaccurate federal student aid records, which could impact student loan repayment status, deferment eligibility, and other Title IV determinations made by the Department of Education. Repeat Finding: Yes Recommendation: We recommend the institution strengthen internal controls over NSLDS enrollment reporting by implementing formal review and reconciliation procedures to ensure: 1. Enrollment dates, program start dates, and enrollment statuses reported to NSLDS agree with institutional records; 2. Enrollment status changes are identified and reported timely; and 3. Enrollment certifications are completed at least every 60 days in accordance with federal requirements. Views of responsible officials: There is no disagreement with the audit finding.