Finding 1221223 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-29
Audit: 405580
Organization: College of Micronesia - Fsm (FM)

AI Summary

  • Core Issue: The College is not updating student enrollment information in the NSLDS, with 53% of campus-level and 17% of program-level records found inaccurate.
  • Impacted Requirements: Compliance with federal enrollment reporting requirements under Title IV HEA is at risk due to inadequate monitoring and update processes.
  • Recommended Follow-Up: Implement a formal process for tracking and updating enrollment statuses, conduct regular reviews, and provide staff training on compliance procedures.

Finding Text

Finding No.: 2025-003 Federal Agency: U.S. Department of Education AL Program: 84.063/84.033/84.007 Student Financial Assistance Cluster Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: NSLDS Reporting Questioned Costs: $-0- Criteria: Institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition: For 32, (or 53%), of 60 students tested, campus level information is not updated in NSLDS. Campus-level record data elements include OPEID number, enrollment effective date, enrollment status and certification date. For 10, (or 17%), of 60 students tested, program level information is not updated in NSLDS. Program-level record data elements include OPEID number, Classification of Instructional Programs (CIP) code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date. Cause: The non-compliance is due to inadequate processes and controls for monitoring and updating students' enrollment status in the NSLDS. This includes delays in processing updates and a lack of oversight to ensure accurate reporting. Effect or potential effect: The College is in noncompliance with applicable enrollment reporting requirements. Identification as a Repeat Finding: Finding No. 2024-007 Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Views of responsible officials The College acknowledges the finding. Refer to corrective action plan.

Corrective Action Plan

Finding 2025-003: Special Tests and Provisions: NSLDS Reporting Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Response: The College concurs with Finding 2025-003 and the auditors’ recommendation. To address this finding, the College has implemented the following actions. Corrective Action Responsible Party Target Date Status Execute formal written agreement between FAO and OARR defining data ownership for each NSLDS record type, update timelines, escalation procedures, and monthly reconciliation responsibilities. Agreement reviewed annually. FAO Director/Registrar/VPEMSS 30 days Draft in progress Implement NSLDS Reporting Calendar aligned to the academic calendar, distributed to FAO, Registrar, and VPEMSS. Built-in reminders at 30, 14, and 7 days before each deadline. FAO Director 30 days Being initiated Implement monthly SIS-to-NSLDS reconciliation. The Financial Aid Office (FAO) will reconcile Student Information System (SIS) data against the NSLDS roster, and any discrepancies will be resolved within five (5) business days. Exception reports will be reviewed and certified monthly by VPEMSS. The monthly reconciliation process will be completed before certification by the VPEMSS, and all identified reporting discrepancies will either be corrected or formally documented with an action plan before certification. FAO Director/Registrar 30 days First cycle underway Coordinate with OARR to verify and maintain accurate CIP codes and credential level data for all active programs at start of each academic year. FAO Director/Registrar 60 days In progress Recruit and fill vacant FAO positions to restore NSLDS processing and monitoring capacity. FAO Director/VPEMSS/HRO 90 days In progress Incorporate NSLDS reporting compliance into annual Title IV self-assessment each August. FAO Director/VPEMSS August 2026 Scheduled Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Within 90 days of the final audit report issuance; NSLDS record updates within 15 days

Categories

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1221221 2025-001
    Material Weakness Repeat
  • 1221222 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $9.77M
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $4.02M
84.425 EDUCATION STABILIZATION FUND $1.41M
10.511 SMITH-LEVER EXTENSION FUNDING $968,436
10.203 PAYMENTS TO AGRICULTURAL EXPERIMENT STATIONS UNDER THE HATCH ACT $773,628
84.047 TRIO UPWARD BOUND $639,518
84.044 TRIO TALENT SEARCH $383,939
93.236 GRANTS TO STATES TO SUPPORT ORAL HEALTH WORKFORCE ACTIVITIES $240,401
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $225,412
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $207,825
84.033 FEDERAL WORK-STUDY PROGRAM $167,402
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $161,685
93.107 AREA HEALTH EDUCATION CENTERS $94,658
10.514 EXPANDED FOOD AND NUTRITION EDUCATION PROGRAM $57,004
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $9,500
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $7,680