Finding 1241796 (2024-015)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2026-11-06
Audit: 415778
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: The College failed to report enrollment information accurately to the NSLDS, affecting compliance with federal requirements.
  • Impacted Requirements: Enrollment statuses must be certified every 60 days, and changes reported within 15 days; errors must be corrected within 10 days.
  • Recommended Follow-Up: Implement internal controls to ensure timely and accurate updates to student status and compliance with federal regulations.

Finding Text

Finding No.: 2024-015 - Special Tests and Provisions – Enrollment Reporting Identification of the federal program: Federal Agency: U.S. Department of Education AL No. and Title: 84.063 Federal Pell Grant Program Federal Award No.: P063Q194572, P063Q204572, P063Q214572, P063Q224572, P063Q234572, P063P224572, P063P234572, P063P244572 Criteria or specific requirement (including statutory, regulatory or other citation): The College is required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, “Campus-Level” and “Program-Level”, both of which need to be reported accurately and have separate types. The Campus-Level Record data elements that ED considers to be high risk are: 1) Office of Postsecondary Education Identification (OPEID) Number; 2) Enrollment Effective Date; 3) Enrollment Status and; 4) Certification Date. The Program-Level Record data elements that ED considers to be high risk are: 1) OPEID Number; 2) Classification of Instructional Programs (CIP) Code; 3) CIP Year; 4) Credential Level; 5) Published Program Length Measurement; 6) Published Program Length; 7) Program Begin Date; 8) Program Enrollment Status and; 9) Program Enrollment Effective Date. In accordance with NSLDS Enrollment Reporting Guide July 2026, at a minimum, schools are required to certify enrollment every 60 days and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS should be corrected and resubmitted within 10 days. Condition: The College did not report the enrollment information in a manner consistent with the above Criteria. Cause: The College lacked established internal control policies and procedures over notification to ED and updating NSLDS of changes in student status in a timely and accurate manner. Effect or potential effect: The College is in noncompliance with applicable special tests and provisions for enrollment reporting requirements. Questioned costs: Not applicable. No questioned cost is presented as the non-compliance was related to reporting requirements. Context: We identified 890 students with status change during the year. We tested 60. The samples were statistically valid. For 37 (or 62%) students tested, the College did not report the enrollment information in a manner consistent with the above Criteria. Details of samples with noncompliance are as follows: a. For 33 (or 55%) students, the enrollment status change was not reported in NSLDS. b. For 1 (or 2%) student, enrollment status reflected in the Campus-Level Record is inaccurate. c. For 3 (or 5%) students, enrollment status change was not certified within 60 days. Identification as a repeat finding, if applicable: 2023-017 Recommendation: College management should establish internal control policies and procedures requiring compliance with applicable federal regulations on notifying ED and updating NSLDS of changes in student status in a timely and accurate manner. Views of responsible officials: The College agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

The College acknowledges the finding and has since strengthened its enrollment reporting practices by continuing to report and update student enrollment information through NSLDS. In addition, the FAO staff responsible for NSLDS enrollment reporting will continue to receive annual training to ensure accurate and timely reporting, strengthen internal controls, and maintain compliance with federal enrollment reporting requirements.

Categories

Student Financial Aid Special Tests & Provisions Reporting

Other Findings in this Audit

  • 1241786 2024-005
    Material Weakness Repeat
  • 1241787 2024-006
    Material Weakness Repeat
  • 1241788 2024-007
    Material Weakness Repeat
  • 1241789 2024-008
    Material Weakness Repeat
  • 1241790 2024-009
    Material Weakness Repeat
  • 1241791 2024-010
    Material Weakness Repeat
  • 1241792 2024-011
    Material Weakness Repeat
  • 1241793 2024-012
    Material Weakness Repeat
  • 1241794 2024-013
    Material Weakness Repeat
  • 1241795 2024-014
    Material Weakness Repeat
  • 1241797 2024-016
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $7.42M
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $2.20M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $721,598
84.047 TRIO UPWARD BOUND $237,825
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $26,277
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $12,552
84.425 EDUCATION STABILIZATION FUND $2,100