Finding Text
Findings and Questioned Costs Relating to Federal Awards Finding No.: 2022-001 ? Special Tests Federal Agency: Department of Education Pass-through Entity: Direct Federal Program: Student Financial Assistance Cluster ? Federal Direct Loan Program, Federal Pell Grant Program Federal AL Number: 84.268, 84.063 Federal Award Numbers: P268K201616, P063P191616 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirement: Special Tests, Enrollment Reporting Criteria or Requirement According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via the National Students Loan Data System (NSLDS) within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NLSDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Additionally, there are two categories of enrollment information within NSLDS, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. Further, 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. Condition Found The College generally certifies its enrollment reports through rosters provided to the NSC. Of the sixty (60) students with enrollment changes we selected for test work, we noted that for six (6) students, the College was notified of the student?s status change and the change was not timely reported to NSLDS. The College did not report the status change until 75-88 days following notification of the change in status.Possible Cause and Effect The College?s internal control processes did not operate consistently to ensure that all enrollment status changes are submitted timely to NSLDS. Delayed submission of student enrollment status information affects the determination that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This finding is a repeat of a finding in the immediately prior audit and the prior year finding number was 2021-003. Recommendation We recommend that the College review its process to ensure that any enrollment changes are reported within the required 30 or 60 day time frame to NSLDS. The College should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. View of College Officials The College recognizes the importance of timely reporting related to student status changes with respect to federal requirements. The College has implemented a manual review procedure that will help to ensure all status changes are reported timely to NSLDS.