Finding 519457 (2024-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-16

AI Summary

  • Core Issue: The College failed to report student enrollment changes to NSLDS accurately and on time, leading to compliance issues.
  • Impacted Requirements: Noncompliance with Uniform Guidance 2 CFR 200.303 and 34 CFR 682.610 regarding timely and accurate reporting of student enrollment statuses.
  • Recommended Follow-Up: Review and improve reporting processes to ensure timely and accurate submissions to NSLDS, as management has acknowledged the issue and is implementing corrective actions.

Finding Text

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said 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: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes; prior year finding number 2023-003 Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.

Corrective Action Plan

2024-003: National Student Loan Data System Condition: The college did not properly report student enrollment changes for students who received federal student aid to NSLDS. Context: During testing of 60 students, 15 students were enrollment changes submitted past 60 days, 6 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 6 had program enrollment effective dates that did not match institutional records, 4 had incorrect program enrollment statuses, and 4 had incorrect program begin dates. Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. View of responsible official: MACC believes some of the current audit finding may be attributed to the SIS system implemented in November 2022; and these finding occurred before we implemented our Corrective Action Plan, which we have faithfully followed every month. As noted below, our CAP is a process in which we review enrollment records reported to NSLDS and update, if needed. Supporting documentation and verification of the work that has been done this past year can be provided, if needed. As a result of the continued commitment to submit correct data from our system to NSLDS every month, this fall MACC paid more than $12,000 to our software vendor (Jenzabar) for enhancements needed to collect, retain and report enrollment data. • Jenzabar created and installed a custom process to update the NSC status start date and NSC program status start date to the Last Date of Attendance. We began running this custom process with the November 2024 NSC enrollment file. • Jenzabar created and installed a custom process to update program begin dates for students returning to the same program to the original program begin date. We have implemented this as a scheduled process beginning December 2024. We are confident future reviews of our NSLDS enrollment reporting records will reflect greater accuracy. MACC would like to note, although the auditors are noting several students with effective date issues and failure to report students timely, we have evidence of student records being exported from our system every month and recorded in the Program Certification Details within NSLDS, but the data is not found in the Program Enrollment Effective Date area of NSLDS. We acknowledge the data must be in both areas of NSLDS, but we believe there is evidence that we submitted our records as required. We are hopeful the new enhancements will correct this issue. As disclosed in our audit response for 2022-2023, the corrective action plan has been slightly altered, but continues: • The Registrar will review data in J1 and submit enrollment records to NSC each month. • The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. • After the enrollment file is accepted by NSC, MACC will review correct enrollment information in NSLDS for all students who have withdrawn from all classes and/or have had an R2T4 calculation, for accuracy. o The Registrar, or designee, will review the data in NSC. o The Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness Reporting

Other Findings in this Audit

  • 519451 2024-001
    Significant Deficiency Repeat
  • 519452 2024-001
    Significant Deficiency Repeat
  • 519453 2024-002
    Significant Deficiency
  • 519454 2024-002
    Significant Deficiency
  • 519455 2024-002
    Significant Deficiency
  • 519456 2024-002
    Significant Deficiency
  • 519458 2024-003
    Material Weakness Repeat
  • 519459 2024-003
    Material Weakness Repeat
  • 519460 2024-003
    Material Weakness Repeat
  • 1095893 2024-001
    Significant Deficiency Repeat
  • 1095894 2024-001
    Significant Deficiency Repeat
  • 1095895 2024-002
    Significant Deficiency
  • 1095896 2024-002
    Significant Deficiency
  • 1095897 2024-002
    Significant Deficiency
  • 1095898 2024-002
    Significant Deficiency
  • 1095899 2024-003
    Material Weakness Repeat
  • 1095900 2024-003
    Material Weakness Repeat
  • 1095901 2024-003
    Material Weakness Repeat
  • 1095902 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $6.50M
84.268 Federal Direct Student Loans $3.27M
84.002 Adult Education - Basic Grants to States $468,377
21.027 Coronavirus State and Local Fiscal Recovery Funds $346,316
84.048 Career and Technical Education -- Basic Grants to States $308,881
11.307 Economic Adjustment Assistance $154,186
84.033 Federal Work-Study Program $150,459
84.007 Federal Supplemental Educational Opportunity Grants $68,608
17.268 H-1b Job Training Grants $57,701
47.076 Stem Education (formerly Education and Human Resources) $6,768
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $336