Finding 1218109 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-22
Audit: 404302
Organization: Chestnut Hill College (PA)

AI Summary

  • Core Issue: The College failed to report certain students' enrollment information accurately and on time to the NSLDS.
  • Impacted Requirements: Regulations require timely reporting of enrollment status changes within 30 or 60 days, and necessary corrections within 10 days.
  • Recommended Follow-up: The College should review and improve its procedures for reporting to the NSLDS, ensuring all information is captured and submitted promptly.

Finding Text

2025–002: National Student Loan Database System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P242088; P268K252088 - 2025 Award Period: July 01, 2024 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the College to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None. Context: During our testing, we noted the following: • 4 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. • 1 student out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the College’s records and the campus-level record in the NSLDS. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2024-004. Recommendation: We recommend the College evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the College review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Finding 2025-002: National Student Loan Database System (NSLDS) Reporting Significant Deficiency in Internal Control over Compliance / Other Matters Views of Responsible Officials and Planned Corrective Actions: Management concurs with the audit findings and acknowledges that controls over accurate and timely reporting of student enrollment information to the NSLDS were not operating effectively, including procedures related to oversight of reporting performed by a third-party servicer. To address this finding, management is implementing the following corrective actions:  Management is evaluating and formalizing its oversight procedures related to NSLDS submissions performed by the third-party servicer, including defined responsibilities, review procedures, and escalation protocols.  Periodic internal reviews of NSLDS submissions are being implemented to verify the accuracy and timeliness of campus-level and program-level enrollment reporting.  Management is updating policies and procedures to ensure that all enrollment status changes and effective dates are captured and reported in accordance with U.S. Department of Education regulations. Management expects these corrective actions to be substantially implemented and will continue to monitor compliance to prevent recurrence.

Categories

Student Financial Aid Reporting Significant Deficiency

Other Findings in this Audit

  • 1218108 2025-002
    Material Weakness Repeat
  • 1218110 2025-003
    Material Weakness Repeat
  • 1218111 2025-003
    Material Weakness Repeat
  • 1218112 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $11.96M
84.063 FEDERAL PELL GRANT PROGRAM $3.03M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $451,047
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $360,477
84.033 FEDERAL WORK-STUDY PROGRAM $224,948
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $113,744
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $11,800