Finding Text
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063
Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC).
Per 2 CFR 200.303, 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 statues, regulations, and terms and conditions of the federal award.
Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 5 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The students’ status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred between 70 and 161 days for the five students from the date of status change.
Questioned Costs: None.
Prevalence: Identified in 5 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample.
Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Cause: The College’s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS.
Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected.
Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.