Finding 1216674 (2023-017)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2026-06-04
Audit: 403112
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: The College failed to report enrollment information for the Pell Grant Program to the NSLDS as required.
  • Impacted Requirements: Compliance with federal regulations for timely and accurate enrollment reporting is lacking, affecting the College's adherence to 34 CFR 690.83(b)(2).
  • Recommended Follow-Up: Implement internal control policies to ensure timely updates to ED and NSLDS regarding student status changes.

Finding Text

Finding No.: 2023-017 Federal Agency: U.S. Department of Education AL Program: 84.063 Federal Pell Grant Program Federal Award No.: P063P214572, P063P224572, P063P234572 Area: Special Tests and Provisions - Enrollment Reporting Questioned Costs: $0 Criteria: The College is required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Per NSLDS Enrollment Reporting Guide February 2026, schools are quired to report details about: 1) The Student – Name, Social Security Number, address, email address, and phone number. 2) The Campus-Level Enrollment for the student – Data related to the student’s overall enrollment at your campus, including Enrollment Status and Effective Date, Anticipated Completion Date, and Certification Date. 3) The Program(s) of Attendance for the student – Classification of Instructional Programs (CIP) code, CIP Year, Program Credential Level, Program Length, Program Enrollment Status, and other data about the program. 34 CFR 690.83(b)(2) states that 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. Condition: The College did not report the enrollment information under the Pell grant via the NSLDS. Cause: The College lacked established internal control policies and procedures over notification to ED and updating NSLDS of changes in student status in a timely and accurate manner. Effect: The College is in noncompliance with applicable special tests and provisions for enrollment reporting requirements. No questioned costs are presented as the finding relates to the reporting compliance requirement. Recommendation: College management should establish internal control policies and procedures requiring compliance with applicable federal regulations on notifying ED and updating NSLDS of changes in student status in a timely and accurate manner. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

Special Tests and Provisions- Enrollment Reporting The College agrees with the finding; however, the issues resulted from a misunderstanding regarding the type of NSLDS documentation requested during the audit process. Enrollment reporting was completed manually through the NSLDS web portal on an individual student basis rather than through batch processing; therefore, batch files were not available to provide during fieldwork. The FAO staff has since received additional guidance and training regarding NSLDS enrollment reporting documentation and audit requirements. The FAO staff will continue participating in training opportunities to strengthen compliance and documentation practices for future audits.

Categories

Student Financial Aid Special Tests & Provisions Reporting

Other Findings in this Audit

  • 1216657 2023-005
    Material Weakness Repeat
  • 1216658 2023-006
    Material Weakness Repeat
  • 1216659 2023-007
    Material Weakness Repeat
  • 1216660 2023-008
    Material Weakness Repeat
  • 1216661 2023-009
    Material Weakness Repeat
  • 1216662 2023-009
    Material Weakness Repeat
  • 1216663 2023-010
    Material Weakness Repeat
  • 1216664 2023-010
    Material Weakness Repeat
  • 1216665 2023-010
    Material Weakness Repeat
  • 1216666 2023-011
    Material Weakness Repeat
  • 1216667 2023-012
    Material Weakness Repeat
  • 1216668 2023-012
    Material Weakness Repeat
  • 1216669 2023-012
    Material Weakness Repeat
  • 1216670 2023-013
    Material Weakness Repeat
  • 1216671 2023-014
    Material Weakness Repeat
  • 1216672 2023-015
    Material Weakness Repeat
  • 1216673 2023-016
    Material Weakness Repeat
  • 1216675 2023-018
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $7.12M
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $2.00M
84.425 EDUCATION STABILIZATION FUND $279,969
84.047 TRIO UPWARD BOUND $236,965
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $133,427
93.107 AREA HEALTH EDUCATION CENTERS $94,309
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $63,681
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $20,517