Finding Text
Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K241902, P268K251902, P063P231902, P063P241902, grants were awarded within the 2023-24 and 2024-25 award years. Award Period: September 1, 2024, through August 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2.) Schools must have some arrangements to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted that 1.) the incorrect enrollment effective date was reported to NSLDS for one out of the 40 students tested 2.) the incorrect program enrollment effective date was reported to NSLDS for two out of the 40 students tested 3.) the incorrect enrollment status was reported to NSLDS for one out of 40 students tested. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that the enrollment effective dates were accurately reported to NSLDS. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Yes – 2024-002. Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.