Findings and Questioned Costs for Federal Awards:
Finding 2024-001: Student Financial Assistance Cluster – Special Tests and Provisions – Enrollment Reporting
Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid
Management’s Views and Corrective Action Plan
Root Causes Analysis: Upon internal review, several key factors contributing to this deficiency were identified:
a. Clearinghouse Processing Gaps: Enrollment reporting at the Academy is managed through the National Student Clearinghouse (NSC), which transmits enrollment updates to the National Student Loan Data System (NSLDS). A review of discrepancies highlighted cases where:
o Student withdrawals were not consistently updated within the mandated timeframe.
o In at least one case, a student was initially listed in NSLDS as “Z – No Record Found” on September 21, 2023, suggesting that NSC added the student to the Academy’s roster. The student withdrew after Fall 2023, but no enrollment update was submitted to NSLDS.
b. Quality Control Mechanism:
o There is currently no established process to cross-check NSC submission data with NSLDS and Student Information System (SIS) records to confirm that all changes were processed correctly.
Corrective Measures: To address this deficiency, the Academy will implement the following corrective actions:
a. Enhanced Collaboration & Process Review (Owner: FA/IT/Registrar, Deadline: April 30, 2025):
o The Financial Aid Office will collaborate with the Registrar’s Office and IT to conduct a thorough review of the NSC reporting process.
o IT will analyze report generation to determine if student records that should be included in NSC updates are being omitted due to system logic or timing of data extraction.b. Quality Control Implementation (Owner: FA/IT, Deadline: May 15, 2025):
o A monthly QC report will be developed to identify students with the NSLDS status “Z – No Record Found” and verify that their enrollment data has been appropriately updated in NSLDS.
o A secondary review of withdrawals, LOAs, and “no-shows” will be completed to confirm their enrollment status changes were transmitted correctly to NSLDS.
c. Manual NSLDS Updates for Withdrawals (Owner: FA, Deadline: Immediate):
o As a temporary solution, the Financial Aid Office will manually update student enrollment statuses in NSLDS following an R2T4 calculation.
o This manual review will act as a safeguard to catch the majority of unreported status changes while a more automated verification process is developed.
Future Process Improvements & Next Steps
a. Automated Data Integrity Checks (Owner: IT, Deadline: June 30, 2025):
o IT will determine whether a custom “NSLDS Status” flag can be implemented in the Academy’s SIS to help identify students whose records do not agree with NSLDS or the NSC report.
b. Ongoing Compliance Monitoring (Owner: FA/IT/Registrar, Deadline: July 30, 2025):
o Academy staff from the Registrar’s Office, Financial Aid, and IT will meet to discuss and document NSC reporting best practices – Internal Procedures, Operational Workflow, Compliance and QC Measures.
o A bi-annual audit of enrollment reporting timeliness will be conducted to ensure continued compliance.
Conclusion: Maine Maritime Academy is committed to ensuring compliance with U.S. Department of Education regulations and providing accurate and appropriate financial aid awards to students. The corrective actions outlined in this plan address the deficiencies identified in the Uniform Guidance audit and aim to prevent similar issues in the future. We appreciate the audit findings and remain dedicated to continuous improvement in our financial aid procedures.