Finding Text
Federal Program: Student Financial Assistance Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Agency: U.S. Department of Education Pass Through Entity: None Federal Award Year: January 1, 2025 to December 31, 2025 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Criteria Requirement: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and verify 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 information. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that the Department of Education (ED) considers high risk: • OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: • OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting Roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting Roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, in accordance with Federal requirements, the College shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition Found: The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the NSLDS. The College receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. For a sample of 60 students who were recipients of Direct Loans or Pell Grants who had been identified as having withdrawn, graduated, or modified their enrollment status as defined by the College’s Satisfactory Academic Progress Policy through a change in course load, the following were noted: • For 5 of the 60 students selected for enrollment reporting testing, management did not report the status change to NSLDS within the required timeframe of 60 days from the date they became aware of the change. • For 8 of the 60 students selected for enrollment reporting testing, the Program Level status was not updated to reflect the appropriate status, therefore management did not report the status change to NSLDS within the required timeframe of 60 days from the date they became aware of the change. Cause and Possible Asserted Effect: The Institution’s controls over the review of the recording and communication of these status changes is not designed effectively to ensure that individuals’ enrollment statuses are completely and accurately communicated to NSLDS on a timely basis. Identification of Questioned Costs: There are no questioned costs related to this finding. Sampling: The sample was not intended to be and was not a statistically valid sample. Identification of Repeat Finding: This audit finding is a repeat of Finding 2024-002 in the immediately prior year. Recommendation: Our recommendation is for management to design and implement a control in order to ensure the compliance requirement objectives are met. In particular, it is advised to implement a system of control within the institution related to the review of enrollment statuses to ensure information is transmitted to NSLDS accurately and timely. Further, management should reinforce and provide training to individuals responsible for compliance control ownership. This will help ensure that there are controls in place to ensure compliance and control ownership is established, thereby preventing or promptly identifying and rectifying instances of noncompliance and ensuring the controls operate as designed. Views of Responsible Officials: The College agrees with the recommendation provided. The College has initiated immediate corrective actions including implementation of proactive controls designed to prevent noncompliance.