Finding Text
Finding 2023-001 - Significant Deficiency: Special Tests and Provisions - Control
Finding
ALN 84.063 - Federal Pell Grant Program and 84.268 - Federal Direct Student Loan
Program - Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Per 34 CFR 682.610 (and further clarified in the
November 2022 National Student Loan Data System (NSLDS) Enrollment Reporting Guide), a
University is required to certify changes in enrollment data for students within 60 days of the
change. Universities are responsible for accurately reporting certain key information, such as
the OPEID number, enrollment effective date, enrollment status, graduation status and
certification date.
Condition: The University recently implemented a revised process and related set of internal
controls to ensure that the required enrollment information is submitted to NSLDS accurately.
While the University’s standard process includes reporting changes in enrollment status every
30 days to the National Student Clearinghouse (NSC), the updated process included fixed dates
for submitting degree verification status updates. Due to multiple start terms (including
variable), and the ability for students to have multiple active programs, the error reports were
quite large; and therefore, the University began quarterly reporting of graduated status to the
National Student Clearinghouse to reduce errors despite the 60-day requirement period.
Cause: The process and related internal controls surrounding enrollment reporting related to
degree verification through NSC were not designed to ensure timely certification of enrollment
reporting changes for graduation statuses, within the 60-day requirement period to NSLDS.
Effect: The University’s controls may not prevent potential errors related to timely certification
of enrollment reporting.
Questioned Costs: Not applicable.
Context: Our audit sample of 40 students did not indicate any instances of noncompliance
related to enrollment reporting. However, our understanding of the process and internal
controls deployed by the University for this compliance requirement did identify a significant
deficiency in the design of the internal controls that indicates a likelihood for noncompliance
with the enrollment reporting requirements is present.
Recommendation: The University should revise the process and internal controls surrounding
enrollment reporting to ensure that all enrollment reporting status changes are certified to NSC
and thereby NSLDS within the 60-day requirement period.
Views Of Responsible Officials: The University acknowledges that the enrollment report
update calendar was set to only certify changes four times per year in the 2022-2023 award
year.