Finding 1214688 (2025-001)

SECTION III – FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS Repeat Finding: No Program Name and Assistance Listing Number: Federal Pell Grant Program – 84.063 Federal Agency: U.S. Department of Education Pass-through Entities: N/A Questioned Costs: N/A FINDING: 2025:001: Noncompliance with NSLDS Enrollment Reporting Requirements Criteria The OMB Compliance Supplement for the Student Financial Assistance Cluster requires that institutions… “accurately notify ED of changes in student enrollment information at the Campus Level and Program Level.” Additionally, Federal Regulation 2 CFR §200.303(a) requires that the Organization… “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.” Condition The Organization did not register for or establish participation in the National Student Loan Data System (NSLDS) during the fiscal year and, as a result, did not implement procedures or controls to report changes in student enrollment information at the Campus Level and Program Level as required. Cause The Organization did not establish policies and procedures to ensure compliance with NSLDS enrollment reporting requirements, as this was the first year of the program and management was not aware that such reporting was required in the absence of Direct Loan activity. Effect The Organization was not in compliance with NSLDS enrollment reporting requirements, which may limit the Department of Education’s ability to monitor student enrollment status and oversee Title IV program activity. Recommendation To address the issue of noncompliance with NSLDS enrollment reporting requirements, the Organization should register with the National Student Loan Data System (NSLDS) and implement policies and procedures to ensure compliance with enrollment reporting requirements, including assigning responsibility for monitoring compliance and maintaining documentation of such reporting. This was fixed after year end. Views of Responsible Officials Management agreed with the assessment and subsequent to year end, steps were taken to correct the matter.