Finding Text
2023-006 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through 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) requires 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. Regulations require the status include an accurate effective date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight
students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Questioned Costs: None
Context: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight students that enrollment was not certified in 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat findings: 2022-005
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.