Finding 1221345 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-30
Audit: 405683
Organization: College of the Muscogee Nation (OK)
Auditor: HOGANTAYLOR LLP

AI Summary

  • Core Issue: Two out of six students had their enrollment status reported late, and four had incorrect enrollment effective dates submitted to NSLDS.
  • Impacted Requirements: Institutions must report accurate enrollment information for Federal Pell Grants in a timely manner as per the Uniform Grant Guidance and NSLDS Enrollment Reporting Guide.
  • Recommended Follow-Up: Financial Aid Coordinator should implement procedures for timely and accurate reporting, including training, clear policies, and automated controls.

Finding Text

Item 2025-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency In accordance with the Uniform Grant Guidance for student financial assistance programs and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, institutions are required to report enrollment information under the Pell grant via the NSLDS. Institutions are responsible for accurately and timely reporting the OPEID number, enrollment effective date, enrollment status and certification date. Out of a sample of six students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. In addition, four students did not have the correct enrollment effective date submitted to NSLDS. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures did not adequately verify the information was submitted to the NSLDS timely and accurately. Finding is a repeat of finding 2024-001 in the immediately prior audit. Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in changes to future awards to the student. We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Corrective Action Plan

Corrective Action Plan (CAP): The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (92 days and 66 days). The statuses of both students are correct with NSLDS. Student 1: Student earned all F grades during the fall 2024 trimester. The student's status was changed to withdrawal in the internal student information system on January 17, 2025. This change was not communicated to NSLDS until the March 2025 enrollment report, due to issues with the February 2025 enrollment report. Student 2: Student was a non-returner in the spring 2025 trimester. The student's status was changed to withdrawal in the internal student information system on January 21, 2025. This change was not communicated to NSLDS until the March 2025 enrollment report, due to issues with the February 2025 enrollment report. The College acknowledges this repeat finding and recognizes that, although the gap was narrowed days beyond tolerance, the prior corrective action plan did not fully resolve the underlying cause of late NSLDS reporting. The previous plan relied primarily on manual identification and status-change processes within the student information system, which remained vulnerable to human error and processing delays. To address this gap, the college will implement a secondary review checkpoint that flags students with status changes in the student information system to ensure timely transmission to NSLDS. To prevent additional recurrences, the College has implemented a monthly reconciliation procedure between the Registrar's Office and the Financial Aid Office, replacing the prior plan's reliance on manual status-chang communication alone. Each month, the Registrar's Office provides a student status change report to the Financial Aid Office. The Financial Aid Office then reconciles each status change against the institution's NSLDS submission history to confirm timely and accurate reporting. This added verification step, paired with documented recordkeeping of each reconciliation cycle, directly addresses the root cause of the repeat finding by introducing a cross-office check that does not depend solely on a single manual status update being correctly carried through to NSLDS reporting.

Categories

Student Financial Aid Subrecipient Monitoring Reporting Significant Deficiency

Other Findings in this Audit

  • 1221346 2025-002
    Material Weakness Repeat
  • 1221347 2025-003
    Material Weakness Repeat
  • 1221348 2025-004
    Material Weakness Repeat
  • 1221349 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.027 ASSISTANCE TO TRIBALLY CONTROLLED COMMUNITY COLLEGES AND UNIVERSITIES $1.84M
84.425 EDUCATION STABILIZATION FUND $1.24M
84.063 FEDERAL PELL GRANT PROGRAM $499,297
84.031 HIGHER EDUCATION INSTITUTIONAL AID $398,719
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $270,836
10.517 TRIBAL COLLEGES EXTENSION PROGRAMS $250,607
10.516 RURAL HEALTH AND SAFETY EDUCATION COMPETITIVE GRANTS $121,019
10.527 NEW BEGINNING FOR TRIBAL STUDENTS $83,160
10.227 1994 INSTITUTIONS RESEARCH PROGRAM $79,082
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $76,492
10.221 TRIBAL COLLEGES EDUCATION EQUITY GRANTS $51,389
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING (INBRE) $49,771
15.820 NATIONAL AND REGIONAL CLIMATE ADAPTATION SCIENCE CENTERS $28,821
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS (FSEOG) $12,566
45.311 NATIVE AMERICAN AND NATIVE HAWAIIAN LIBRARY SERVICES $9,935
12.598 CENTERS FOR ACADEMIC EXCELLENCE $9,582
10.311 BEGINNING FARMER AND RANCHER DEVELOPMENT PROGRAM $2,500
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $104