Finding 504669 (2024-001)

2024 – 001: Special Tests and Provisions – NSLDS Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P231544, P268K241544 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), 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 statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 685.309(b), states that: Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported in NSLDS. Questioned costs: None Context: The enrollment data was incorrectly reported for 1 out of 60 students. Cause: The student’s enrollment status update was delayed due to the sequence of file submissions by the college. Although the college transmitted accurate information with each Spring 2024 enrollment file, the initial sequencing of the Fall 2023 graduation file led to a delay in updating the student’s enrollment status and effective date in NSLDS until Fall 2024. Effect: Student enrollment status was not reported accurately in NSLDS. Repeat Finding: No Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.