Finding Text
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? 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 Reporting Roster file or 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 Reporting Roster, or 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 that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. 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. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. 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. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to 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, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.