Finding Text
2022-005 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: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded. Questioned Costs: None Context: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. 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: 2021-007 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.