Finding Text
Criteria
Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan
programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and
timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify
student enrollment statuses, program information, and effective dates that appear on the Enrollment
Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access
(NSDLSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program
Level,” both of which need to be reported accurately and have separate record types.
Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, section 303(a) states, the 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 statues, 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).
Condition
In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are:
OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement,
Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment
Effective Date.
Of the 40 students with enrollment changes that we selected for testwork, KPMG identified 2 students
whose program level enrollment data elements were not accurately transmitted to NSLDS. Specifically,
KPMG identified that 2 students’ Published Program Lengths, as reported to NSLDS, did not agree to the
College’s records.
The exceptions described above did not result in changes to the amounts awarded or disbursed to students
by the College for the current fiscal year.
Cause
The condition resulted from the College’s internal control processes not operating consistently to ensure
that all changes in enrollment information at both a campus level and program level were accurately
reported to NSLDS. Specifically, the College’s control of reviewing the key enrollment reporting data
elements for accuracy was not operating at a level of precision that would cover all key data elements.
Possible Asserted Effect
Inaccurate submission of student enrollment status information and related program information affects the
determinations that lenders and servicers of students’ loans make related to in-school status, deferments,
grace periods, and repayment schedules, as well as the federal government’s payment of interest
subsidies. Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend the College review and enhance its process related to enrollment reporting to ensure that
all status change key data elements that are reported to NSLDS agree to the College’s records.
Views of Responsible Officials
Management concurs with the recommendations provided. The Registrar’s Office will implement a
reconciliation of the Student Enrollment Information system and data provided to NSC (the National
Student Clearinghouse). The reconciliations will be reviewed by the Associate Registrar and confirmed by
the Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any
discrepancies will be sent to NSC immediately informing them of any necessary corrections.
Estimated Date of Completion: March 31, 2025