Finding 502653 (2024-001)

Significant Deficiency

Requirement

Questioned Costs

Year

2024

Accepted

2024-10-14

Audit: 324653

Organization: Trustees of Grinnell College (IA)

Auditor: Cliftonlarsonallen LLP

AI Summary

Core Issue: The College failed to report student enrollment data accurately and on time to NSLDS, leading to discrepancies in effective dates.
Impacted Requirements: Non-compliance with 34 CFR 685.309(b) regarding timely reporting of enrollment status changes.
Recommended Follow-Up: The College should review and improve its procedures for reporting enrollment changes to ensure accuracy and compliance with federal regulations.

Finding Text

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted for 2 out of the 40 students tested, the enrollment effective date did not match the College's records. Furthermore, we noted 2 out of the 40 students tested where the student was not reported in a timely manner. Questioned Costs: None reported. Context: During our testing, it was noted the University’s current process in place did not ensure timeliness and accuracy of NSLDS reporting. Cause: The College did not have a process in place to ensure the effective dates reported matched the College's records as well as that these changes were reported timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. In addition, the College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus level is aligning with the College as well as the status changes are reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus level is aligning with the College as well as the status changes are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The College utilizes a custom report for enrollment reporting to the National Student Clearinghouse (NSC), who then provides data to NSLDS. In recent years the custom report has required additional manual updates. Ellucian, who provides the Colleague system that the Office of the Registrar uses as their system of record, provides quarterly updates to the Colleague code. Each system update results in necessary review and insertion of the custom report into the Colleague process. The College’s Chief Information Officer has approved funding to contract with a NSC Specialist from Ellucian during Fall 2024 to review Grinnell’s enrollment reporting process and to determine what changes should be made within the Colleague system to make the enrollment reporting process less manual. This would improve the accuracy of reporting by eliminating the constant review and manual adjustments the current process requires. Name(s) of the contact person(s) responsible for corrective action: Jason Luedtke, Senior ERP Specialist, Information Technology Services Planned completion date for corrective action plan: Spring 2025.

Other Findings in this Audit

502654 2024-001

Significant Deficiency
502655 2024-001

Significant Deficiency
502656 2024-001

Significant Deficiency
502657 2024-001

Significant Deficiency
1079095 2024-001

Significant Deficiency
1079096 2024-001

Significant Deficiency
1079097 2024-001

Significant Deficiency
1079098 2024-001

Significant Deficiency
1079099 2024-001

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
84.268	Federal Direct Student Loans	$2.53M
84.063	Federal Pell Grant Program	$1.78M
84.038	Federal Perkins Loan Program	$639,916
84.007	Federal Supplemental Educational Opportunity Grants	$230,720
84.033	Federal Work-Study Program	$200,000
47.070	Computer and Information Science and Engineering	$167,116
47.049	Mathematical and Physical Sciences	$153,193
45.149	Promotion of the Humanities_division of Preservation and Access	$79,784
10.890	Rural Development Cooperative Agreement Program	$65,962
47.050	Geosciences	$39,774
47.074	Biological Sciences	$28,320
47.076	Education and Human Resources	$24,005
45.169	Promotion of the Humanities_office of Digital Humanities	$17,507
47.083	Integrative Activities	$11,382