Finding 541990 (2024-004)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 350797
Organization: College Unbound (RI)

AI Summary

  • Core Issue: The College failed to report student enrollment changes to the NSLDS on time, with delays ranging from 19 to 116 days for 6 out of 16 students.
  • Impacted Requirements: Compliance with federal regulations requires timely and accurate reporting of enrollment status changes to avoid affecting students' loan grace periods.
  • Recommended Follow-Up: Strengthen internal controls to ensure compliance with NSLDS reporting requirements and prevent future delays.

Finding Text

Finding number: 2024-004 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 6 out of 16 students were reported late to the NSLDS by 19 to 116 days and 1 out of 16 students reported an incorrect effective date to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2023-006 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Corrective Action Plan: Previously, this was an ancillary work task for a staff member in a different department. CU has since hired an experienced Registrar and begun training an Associate Registrar. The dedicated department now updates Clearinghouse on the required monthly basis. All previous records have been corrected. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Mark Hartonchik, CFO

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 541987 2024-003
    Significant Deficiency
  • 541988 2024-002
    Significant Deficiency
  • 541989 2024-003
    Significant Deficiency
  • 1118429 2024-003
    Significant Deficiency
  • 1118430 2024-002
    Significant Deficiency
  • 1118431 2024-003
    Significant Deficiency
  • 1118432 2024-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.09M
84.063 Federal Pell Grant Program $1.85M
21.027 Coronavirus State and Local Fiscal Recovery Funds $576,630
84.425 Education Stabilization Fund $440,960
84.116 Fund for the Improvement of Postsecondary Education $206,693
84.007 Federal Supplemental Educational Opportunity Grants $23,394
84.033 Federal Work-Study Program $18,022