Finding Text
Finding number: 2023-006
Federal agency: U.S. Department of Education
Programs: Student Financial Assistance Cluster
Assistance listing #: 84.063 & 84.268
Award year: 2023
Compliance requirement: Special Tests
Criteria
According to 34 CFR 685.309(b)(2):
Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that -
(i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
(ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website.
Condition
The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 2 out of 10 students were reported late to the NSLDS by 35 to 96 days and 4 out of 10 students reported an incorrect effective date to the NSLDS. Additionally, 1 out of 10 students had an incorrect status change reported to the NSLDS. Our sample was not, and was not intended to be, statistically valid.
Cause
The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately.
Effect
Late or incorrect effective dates may impact the students’ loan grace periods.
Questioned Costs
Not applicable.
Identification as a Repeat Finding, if applicable
See finding 2022-007 included in the summary schedule of prior year findings.
Recommendation
The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations.
View of Responsible Officials
The College agrees with the finding.