Finding Text
US DEPARTMENT OF EDUCATION
Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268
Special Tests and Provisions – Enrollment Reporting
Significant Deficiency in Internal Control over Compliance
Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS).
Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Maintenance page is what NSLDS has as the most recently certified enrollment information. 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 over the NSLDS reporting requirements, we noted 3 students’ enrollment status out of the 40 students tested where the reporting was either missing or did not agree to the actual enrollment status submitted to NSLDS.
Cause: The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely and accurate in all cases. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Effect: The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education.
Questioned Costs: None reported
Context/Sampling: The College disbursed Federal financial aid to approximately 801 students in the 2023-2024 school year. A non-statistical sampling of 40 students was selected for testing.
Repeat Finding: No
Auditor’s recommendation: The College should implement additional processes to review, update, and verify student enrollment statuses, program information, and the effective dates that appear in the enrollment reporting in the NSLDS and assign staff to follow up on student status errors in NSLDS.
Management’s response: To address enrollment reporting discrepancies identified in the auditor’s report, and to mitigate such enrollment status discrepancies from occurring going forward, TVCC has taken the following actions:
1. Properly updated the enrollment status of each of the three (3) identified students in the National Student Clearinghouse (NSC) via NSC’s “Student Lookup” tool.
2. Identified and implemented a mechanism to correct the enrollment status issues caused by TVCC’s issuance of Career Pathways Certificates (CPCCs).
3. Requested and was granted an assigned NSC staff member to handle the processing of our enrollment report submissions and error resolution reports.
4. The Registrar’s Office and Financial Aid Office are also working with the Enterprise Systems Support Analyst to implement an internal audit tool/process that will allow us to better screen our enrollment and graduate reports prior to submission to NSC.