Finding Text
FINDING 2023-002 – Enrollment Reporting
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063
Federal Program Name: Federal Pell Grant Program
Award Year: 2021-22
Criteria: Pell Grant, Section 34 CFR Section 690.83(b)(2): An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Condition and context: In fiscal year 2023, the College implemented many new controls which were communicated in the previous corrective action from the preceding year. One area that was not implemented was a control related to the review by the Financial Aid Manager of the prepared Roster File prior to submission. MA noted that the control was not operating as designed since NSLDS submissions were both prepared and submitted by the same person during the current year.
Questioned costs: None.
Cause: A person other than the Financial Aid Manager was not designated to prepare the submissions.
Effect: Because of the lack of a review by an individual independent of the preparer, errors could occur and not be identified prior to submission. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. However, American Samoa Community College doesn’t participate in loan programs, which limits the effect of non-compliance.
Repeat finding: Yes
Recommendation: We recommend the College ensure the policy is being followed which requires a review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we recommend the College retain documentation reflecting all formal reviews of the roster.
Views of responsible officials and planned corrective actions: The Financial Aid Coordinator (control #1, with FA Officer as alternate) has been assigned to transmit the bi-monthly Enrollment Report roster. The control #1 reviews the roster and performs data entry, status updates, and submission by the 15th of the reporting month.
On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th.
Financial Aid Manager (control #2) will review the status updates on NSLDS before and after every submission. Identified errors will be documented and returned to control #1 for correction and resubmission. The policy will ensure all student changes in status are identified, updated, and submitted timely and accurately.
ASCC FAO participates in Federal Student Aid (FSA) training and conferences regarding NSLDS updates, changes, and functionality. FAO also subscribes to the Weekly Knowledge Center Updates from FSA Partner Connect. ASCC is a member of the National Association of Student Financial Aid Administrators (NASFAA). All of these resources provide access and education in the process of enrollment reporting and compliance, as well as the responsibilities and consequences of inaccurate reporting.
Graduates: Students who graduate will be updated into NSLDS within one week after graduation.
Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days.
On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th.
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le’i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs