Finding 2022-001 ? N4. Enrollment Reporting Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: ?The non-Federal entity must: (a) 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 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).? Condition: There was no evidence that an authorized individual was reviewing the monthly SFRNSLC enrollment report for completeness and accuracy prior to its upload to the National Student Clearinghouse (NSC)/National Student Loan Data System for the period January 1, 2022 through September 30, 2022. Cause: Although a review of the enrollment report was performed by the Registrar, there was no formal documentation retained for the period January 1, 2022 through September 30, 2022, to evidence the procedures performed, what information was evaluated, the precision of the review, what types of noncompliance were identified, and what actions were taken to address any issues identified. Effect or potential effect: An incorrect enrollment report may be submitted. Questioned costs: None. Context: Management implemented internal controls on October 1, 2022, to include a monthly review of at least 12 students for accuracy and completeness. This control was tested for the period October 1, 2022 through December 31, 2022, and determined to be operating effectively. Total Federal Pell Grants and Federal Direct Loans for GSON were $845,056 and $6,869,688, respectively, representing 10.8% and 87.7%, respectively, of total Student Financial Assistance Cluster federal expenditures of $7,830,734. Identification as a repeat finding, if applicable: This is a partial repeat finding and is related to finding 2021-001 from the prior year. Recommendation: Management should continue to follow its internal control implemented on October 1, 2022, which documents the review process performed by the Registrar, including the students sampled and the specific data validated, the results of the review, and the follow-up actions taken, if any, and sign-off by the Registrar to evidence performance of the monthly review. Views of Responsible Officials: Management agrees with the finding and will continue to follow the internal control implemented in October 2022.