Finding Text
Reference Number: 2023-001
Federal Agency: U.S. Department of Education
Federal Program: Student Financial Aid
Assistance Listing Number: 84.063, 84.268
Award Number and Period: P063P221553 and P268K231553 (July 1, 2022 – June 30, 2023)
Compliance Requirement: Special Tests – Enrollment Reporting
Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters
Criteria
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, 34 CFR 685.309(b), states that:
• Colleges must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The college 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 college must report accurately the enrollment status of all students regardless if they receive aid from the institution or not.
• Colleges must have some arrangement to report student program enrollment effective date and status to NSLDS.
Condition
Incorrect enrollment status and effective dates were reported to NSLDS.
Context
The enrollment status was incorrectly reported for 1 out of 40 students. The effective date was incorrectly reported for 1 out of 40 students.
Cause
The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status and effective dates were uploaded to NSC timely, however, monitoring of the upload through success was inconsistent. No review was completed to ensure the upload was completed and accurate in NSLDS.
Effect
Student enrollment status and effective dates were not reported accurately to NSLDS.
Repeat Finding
No
Questioned Costs
None
Recommendation
The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS.
Views of Responsible Officials
There is no disagreement with the audit finding.