Finding Text
Criteria
According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days to ensure attendance changes for students are reported within 60 days of the change. An institution must notify the Secretary of Education if it discovers that 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.
Further, in accordance with 2 CFR 200.303(a), non-Federal entities 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 the 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).
Condition Found
During our audit we found one (1) of forty (40) students selected for testing whose change in enrollment status was not timely transmitted to NSLDS. KPMG notes that for this exception, the College reported the status change 144 days after they became aware of the status change. In addition, we identified two (2) of forty (40) students selected whose enrollment status was incorrectly reported. In all instances, the College reported the student as withdrawn, however, the student had graduated from the College.
Possible Asserted Effect
Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government's payment of interest subsidies.
Questioned Costs
No questioned costs identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This was not a finding in the prior year.
Recommendation
We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 60-day time frame. The College should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected.
View of College Officials
The identified conditions relate to students who graduated off-cycle. To mitigate the risk of future status change reporting issues, the College is implementing an additional monthly review process that will generate a report of students who have separated from the College. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made immediately. These corrective actions are being implemented in Spring 2025.