Finding Text
Federal agency: U.S. Department of Education
Federal program title: Student Financial Aid Cluster
ALN Number: 84.063, 84.268
Federal Award Identification Number: P063P221568, P063P231568, P063Q221568, P063Q231568,
P268K231568, P268K241568
Award Period: July 1, 2023 June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement:
Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the
terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in Standards for Internal Control in the Federal Government issued by the Comptroller
General of the United States or the Internal Control Integrated Framework, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance:
1. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2),
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. Additionally, schools are required to certify
enrollment at a minimum of every 60 days or every other month.
2. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2),
requires certain student enrollment information be reported to the Department of Education.
Information provided to the Department of Education should agree to the institutions records.
Condition: The change in status was not reported timely and the program begin date per the
institutions records did not agree to information in the NSLDS.
Questioned costs: None
Context: This condition occurred in our statistically valid sample as follows:
1. The status was not reported timely for 4 out of 36 students
2. The Program Begin Date was incorrectly reported for 7 out of 35 students
Cause: The Registrar's Office has been through several transitions over the past five years and training
has been inadequate during this period. Specifically, there was not sufficient training on enrollment
submissions, error resolutions, and timely updates.
Effect:
1. The published program length reported to NSLDS is used to determine the students maximum
and remaining eligibility periods under the 150% limit. By not reporting the correct length, the
calculation of the 150% would be incorrect and the grace period begin date would be incorrect.
2. The NSLDS system is not updated timely with the student information which may cause over
awarding should the student transfer to another institution and the students may not properly
enter the repayment period.
Repeat Finding: Yes, 2023-001
Recommendation: We recommend the College review its reporting procedures to ensure that
students statuses are accurately and timely reported to NSLDS as required by regulations.
Views of responsible officials: There is no disagreement with the audit finding.