Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268; 84.007
Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 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. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award (2 CFR 200.303).
Condition: 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). We identified the following items of noncompliance:
8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2))
1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2))
Questioned costs: None
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above.
Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to
ensure that reporting is completed accurately and timely.
Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.