Finding Text
2023-005 Special Tests and Provisions
Federal agency: U.S Department of Education
Federal program title: Student Financial Assistance Cluster
Assistant Listing Number: 84.007/84.033/84.063/84.268
Federal Award Identification Number: P007A221105 - P033A221105 - P063P221336 - P268K231336
Award Period: July 1, 2022 to June 30, 2023
Type of Finding:
• Compliance, Other Matters
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days.
The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 40 students, we identified 5 students that were reported past the 60-day reporting timeframe to NSLDS. These student enrollment dates were reported 12 days late.
Questioned costs: None.
Cause: The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner.
Effect: Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely.
Views of responsible officials: Management agrees with the finding.