Finding Text
Criteria or specific requirement:
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).
Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file.
Condition: We identified one instance where a student’s program enrollment effective date did not match the institution’s records. Internal controls in place did not catch this instance.
Context: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Out of a sample of 40 enrollment changes selected for testing for the requirements noted above, we noted one student where a student’s program enrollment effective date did not match the institutions records. In addition, during internal control testing, we noted that for the year under audit, internal controls over enrollment reporting were maintained in the College’s legacy information technology system. However, given conversion to a new system had occurred, evidence of key internal controls was not readily available.
Questioned costs: None.
Cause: The College was unaware that the date pulled from Banner did not match the records reported to NSLDS and internal controls in place did not catch this instance.
Effect: The NSLDS system enrollment effective date did not match the College’s records, which is not in compliance with the regulations described above.
Repeat Finding: No.
Recommendation: We recommend that the College enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately.
Views of responsible officials: Management agrees with the finding.