Finding Text
2023-007 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: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 – NSLDS tracks how many students, included on a
school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine
whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2).
Condition: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Questioned Costs: None
Context: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
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: 2022-006
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.