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FINDING 2025‐002 – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is the College’s responsibility to update this information timely and accurately. The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. Condition and context: 2 submissions of official withdrawals were reported late and not identified prior to submission. 1 submission of a graduated student was not reported timely and not identified prior to submission. 1 submission of an unofficial withdrawal was reported late and not identified prior to submission. 26 students were sampled using a random sampling methodology from a population of 65 withdrawals, and 170 graduates. American Samoa Community College (A Component Unit of the American Samoa Government) Schedule of Findings and Questioned Costs Year Ended September 30, 2025 48 Questioned costs: None. Effect: This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. However, American Samoa Community College does not participate in loan programs, which limits the effect of non-compliance. Cause: In 2025, additional controls were implemented, including the reconciling of uploaded reports. Unfortunately, this reconciliation was external report to external report, which was not able to identify students who attended and withdrew from the school during the same enroll roster reporting period. As such, this reconciliation was not able to identify these students timely, which resulted in unidentified and late submission. Repeat finding: Yes. Recommendation: We recommended the College ensure the policy is being followed, which requires a review to be performed independent of the individual who prepares the NSLDS roster. We also recommended the College compare internal student rosters to external roster reports to ensure the rosters are complete and accurate in regard to students reported as graduated or withdrawn. Additionally, we recommend the College retain documentation reflecting all formal reviews of the roster. This recommendation was made in the prior year but not effectively, and correction of the reconciliation was necessary. Views of responsible officials and planned corrective actions: The Financial Aid Office ensures strict adherence to NSLDS reporting timelines. Institutionally, enrollment is certified monthly and the school responds within 15 days of the date NSLDS issues a roster file. Any errors identified through the NSLDS are reviewed, corrected and resubmitted within 10 days. To strengthen accuracy, completeness, and compliance, the Financial Aid Office has implemented a dual-review control system. Contact Person(s): Shanell Tilo, Financial Aid Officer Dr. Emilia Le’i, Dean of Student Services Dr. Letupu Moananu, Vice President of Academics, Community, and Student Affairs