Finding 517587 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-03
Audit: 335602
Organization: Thomas College (ME)
Auditor: Wipfli LLP

AI Summary

  • Core Issue: The College failed to accurately report student enrollment status changes to NSLDS, with 2 out of 40 files tested showing errors.
  • Impacted Requirements: Compliance with 34 CFR 685.309, which mandates timely and accurate reporting of enrollment status changes.
  • Recommended Follow-Up: Enhance internal controls to ensure all submissions to NSLDS are reviewed for accuracy and submitted on time.

Finding Text

Finding 2024-002 Repeat Finding: No Major Programs: 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2023 to June 30, 2024 Compliance Requirement: Special Tests – Enrollment Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Other matters Questioned Costs: None Criteria: The Code of Federal Regulations, 34 CFR 685.309 requires that 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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition and Context: The examination disclosed 2 instances out of 40 student files tested in which NSLDS was not updated correctly. The institution did not accurately report the most recent status of the students. Effect: The inaccurate status may effect the student’s future Title IV funding. Cause: It appears the College’s third-party servicer National student Clearing Clearinghouse (NSC) had a breakdown in the communication to NSLDS. Recommendation: We recommend that the College enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. View of responsible officials: The College agrees with the finding and are committed to a corrective action.

Corrective Action Plan

Thomas College has refined internal reporting policies and procedures to confirm that student enrollment is reported accurately and in a timely manner. The College uses the National Student Clearinghouse as a data vendor for reporting to NSLDS. The College agrees the students were incorrectly report to NSLDS. However, the student records were regularly updated with the National Student Clearinghouse, according to policies and procedures, NSC was not then transmitting some student records to NSLDS due to a conflict in data reported by a prior instituition concerning name and mismatched SSN. The College has identified the error within the National Student Clearinghouse (NSC). The following findings and corrective actions have been adopted: 1) Additional one on one training with the NSC has been completed to better understand the cause of the finding. The error that is preventing the release of information to NSLDS has been identified and steps required to resolve the error have been communicated. This training will expand to all Thomas College employees who oversee and process enrollment reporting. 2) Thomas College is closely monitoring the processing details from each submission file sent from the college to NSC to identify students not being sent from NSC to NSLDS. Thomas College is submitting the necessary, required paperwork for verification to the NSC, as needed; to verify the student's identify and information, an example of this documentation is an ISIR recorded provided by SFS. The NSC send an automated email to enrollment reporting staff when changes are made and a follow up email requesting additional information if needed. Once resolved, student are no longer shown on the transmission rejection list and are being sent to NSLDS.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions Reporting Significant Deficiency

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $5.05M
84.063 Federal Pell Grant Program $1.52M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.23M
84.116 Fund for the Improvement of Postsecondary Education $301,656
84.031 Higher Education_institutional Aid $263,996
84.007 Federal Supplemental Educational Opportunity Grants $248,573
84.042 Trio_student Support Services $229,573
84.033 Federal Work-Study Program $149,198
84.038 Federal Perkins Loan $35,430