Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants
84.033 – Federal Work Study Program
84.038 – Federal Perkins Loans
84.063 – Federal Pell Grant Program
84.268 – Federal Direct Student Loans
84.379 – Teacher Education Assistance for College and Higher Education Grants
Federal Award Identification Number and Year: N/A
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2022 to June 30, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. 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.
Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated.
Questioned Costs: None
Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner.
Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly.
Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, Finding 2022-002.
Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.