Finding Text
Finding No.: 2025-004 – Enrollment Reporting- Significant deficiency Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN Number: Various Federal Award Year: July 1, 2024 – June 30, 2025 Criteria In accordance with 2 CFR 200.303(a), non-Federal entities 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. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our enrollment reporting testing we identified the following: (1) For 9 of 60 students selected for testing, the student’s graduation or withdrawal status was not updated within 60 days, the required timeframe to be reported to the NSLDS. The student’s identified had been granted extension periods to complete coursework. (2) For 1 of 60 students selected for testing the enrollment status in the NSLDS did not agree to the College’s internal records. (3) For 4 of 60 students selected for testing the College’s records lacked sufficient evidence to demonstrate when the institution became aware of the students’ status changes. Cause The cause of this noncompliance was a control deficiency in which the institution lacked sufficient monitoring, documenting, and review procedures over student enrollment status changes reported to the NSLDS. The engagement team notes that the institution did not have a reconciliation process to ensure status updates, specifically graduation and withdrawal dates, were accurately tracked and reported within the required timeframes, particularly when coursework extension periods were granted. Additionally, the institution lacked a formal review mechanism to cross-reference NSLDS records against internal databases to identify individual discrepancies, as well as a standardized procedure to document and retain the specific dates on which official status change notifications were received. Possible Asserted Effect Failure to perform review procedures over enrollment reporting changes could result in reporting more or less students enrolled receiving financial aid than what true enrollment is which could result in students receiving aid when not required or failure to receive aid from the Department of Education. Questioned Costs Not applicable. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The conditions found constitute a repeat finding from the prior year. Recommendation We recommend that management implement a monitoring and review process to ensure all student enrollment status changes are accurately and timely transmitted to the NSLDS. Specifically, management should establish a formal tracking mechanism for students granted coursework extensions to ensure their graduation or withdrawal dates are updated within required timeframes, and design a monthly reconciliation procedure to cross-reference NSLDS records against internal student databases to identify and resolve any individual discrepancies. Additionally, management should implement a standardized document retention policy to consistently record and preserve the dates the institution becomes aware of student status changes to ensure compliance with federal reporting deadlines. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.