Finding 522789 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-12
Audit: 342163
Organization: Bay Mills Community College (MI)

AI Summary

  • Core Issue: The College failed to report student status changes accurately to the NSLDS, with 9 out of 40 cases noncompliant.
  • Impacted Requirements: Institutions must report enrollment information accurately under Pell grant regulations (34 CFR 690.83(b)(2)).
  • Recommended Follow-Up: Establish a withdrawal policy and improve processes for verifying data submitted to NSLDS.

Finding Text

2024-001 - Status Change Reporting Issues. Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Number 84.063; Award Number P063P234637. Criteria. Institutions are required to report enrollment information under the Pell grant program via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2)). Institutions must review, update, and verify 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 (NSLDSFAP) 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition. During our testing of the Pell Grant program, we selected a sample of forty students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Of the forty tested, nine were out of compliance based on the criteria outlined in the Department of Education's Code of Federal Regulations at 34 CFR 690.83(b)(2). Cause. The College did not have a policy for administratively withdrawing students who ceased attending classes, which hindered their ability to report the student status changes to NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS system may not be updated with correct student information, which may cause over subsequent awarding issues or loan repayment term discrepancies. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College establish a withdrawal policy to improve the accuracy of their status change reporting. We also recommend enhanced processes for reviewing and verifying the accuracy of data submissions to NSLDS. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Bay Mills Community College Single Audit report for the year ended June 30, 2024, and corrective actions to be completed. 2024-001 – Status Change Reporting Issues. Auditor Description of Condition and Effect. During our testing of the Pell Grant program, we selected a sample of forty students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Of the forty tested, nine were out of compliance based on the criteria outlined in the Department of Education's Code of Federal Regulations at 34 CFR 690.83(b)(2). As a result of this condition, the NSLDS system may not be updated with correct student information, which may cause subsequent awarding issues or loan repayment discrepancies. Auditor Recommendation. We recommend that the College establish a withdrawal policy to improve the accuracy of status change reporting. We also recommend enhanced processes for reviewing and verifying the accuracy of data submissions to NSLDS. Corrective Action. The College has implemented an Administrative Withdrawal Policy, approved by the Board of Regents on November 15, 2024. This policy will enhance the identification and reporting of students who cease attending classes. Additionally, the College will receive a Roster Response file from the National Student Clearinghouse, containing the full dataset sent to NSLDS, which will be reviewed for accuracy. Responsible Person. Katie Corbiere, Director of Financial Aid. Anticipated Completion Date. June 30, 2025

Categories

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

Other Findings in this Audit

  • 522790 2024-001
    Significant Deficiency
  • 1099231 2024-001
    Significant Deficiency
  • 1099232 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.39M
84.425 Education Stabilization Fund $952,811
84.031 Higher Education Institutional Aid $557,387
93.600 Head Start $348,568
10.221 Tribal Colleges Education Equity Grants $244,928
84.042 Trio Student Support Services $236,300
84.048 Career and Technical Education -- Basic Grants to States $199,292
10.766 Community Facilities Loans and Grants $189,994
10.222 Tribal Colleges Endowment Program $106,315
10.500 Cooperative Extension Service $99,546
10.215 Sustainable Agriculture Research and Education $94,017
15.027 Assistance to Tribally Controlled Community Colleges and Universities $61,982
84.007 Federal Supplemental Educational Opportunity Grants $25,000
84.033 Federal Work-Study Program $25,000
47.076 Stem Education (formerly Education and Human Resources) $11,673
10.227 1994 Institutions Research Grants $8,085
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $1,084
21.027 Coronavirus State and Local Fiscal Recovery Funds $110