Finding Text
Federal agency: U.S. Department of Education
Federal program title: Student Financial Aid Cluster
CFDA Number: 84.063, 84.268
Federal Award Identification Number: P063P221568, P268K231568
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement:
Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity 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 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).
Compliance:
1. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled
transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month.
2. Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows:
a. If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.
b. If the school has not published a program length and the program is an associate or bachelor’s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the
program makes it longer or shorter than typical.
c. For all other programs for which the school has not published a program length, the program length is based on the school’s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete.
Condition: The change in status was not reported timely and the incorrect program length was reported to NSLDS.
Questioned costs: None
Context: This condition occurred in our statistically valid sample as follows:
1. The status was not reported timely for 33 out of 35 students
2. The Program Length was incorrectly reported for 35 out of 35 students
Cause: The Registrar's extended absences and sudden medical leave caused significant disruptions to the College’s operations, resulting in a delay in securing a temporary replacement from the Registry. Unfortunately, the Registrar has since resigned, and the College is currently in the process of searching for a suitable replacement.
Effect:
1. The published program length reported to NSLDS is used to determine the student’s maximum and remaining eligibility periods under the 150% limit. By not reporting the correct length, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect.
2. The NSLDS system is not updated timely with the student information which may cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: Yes, 2022-002
Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of responsible officials: There is no disagreement with the audit finding.