Finding 566941 (2024-001)

Significant Deficiency

Requirement

Questioned Costs

Year

2024

Accepted

2025-06-25

Audit: 359811

Organization: College of the Muscogee Nation (OK)

Auditor: Hogantaylor LLP

AI Summary

Core Issue: Two out of nine students' enrollment statuses were not reported to NSLDS on time, leading to potential inaccuracies in Pell Grant eligibility.
Impacted Requirements: Institutions must report enrollment data accurately and promptly to comply with Uniform Grant Guidance for federal student aid programs.
Recommended Follow-up: Implement procedures to ensure timely and accurate reporting of student statuses, including training and automated controls.

Finding Text

Finding: Item 2024-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In accordance with the Uniform Grant Guidance for student financial assistance programs, institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following data to the Department of Education: OPEID number, enrollment effective date, enrollment status and certification date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition / context: Out of a sample of nine students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify the information was submitted to the NSLDS timely. Repeat finding: Not a repeat finding. Effect: Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in an over award of Pell Grant to the student. Recommendation: We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Corrective Action Plan

The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (102 days and 69 days). The statuses of both students are correct with NSLDS. Student 1: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enollment status and subsequent R2T4 calculation (as noted in finding 2024-002) was delayed. Student 2: Student graduated, and status was updated with NSLDS at 69 days. Due to delayed communication and delayed reporting to NSLDS, CMN will revise institutional policy to clearly define the process and timeline for enrollment status changes. Financial aid staff will seek additional training in enrollment reporting through FSA and/or NSFAA. To further monitor compliance, CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. This electronic, automatic process will provide an additional layer of notification to the financial aid office when a student status change requires further attention.

Other Findings in this Audit

566942 2024-002

Significant Deficiency Repeat
566943 2024-003

Significant Deficiency
1143383 2024-001

Significant Deficiency
1143384 2024-002

Significant Deficiency Repeat
1143385 2024-003

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
15.027	Assistance to Tribally Controlled Community Colleges and Universities	$1.53M
84.031	Higher Education Institutional Aid	$1.08M
10.766	Community Facilities Loans and Grants	$508,910
84.063	Federal Pell Grant Program	$456,815
93.243	Substance Abuse and Mental Health Services Projects of Regional and National Significance	$355,653
84.425	Education Stabilization Fund	$268,318
10.517	Tribal Colleges Extension Programs	$254,938
10.516	Rural Health and Safety Education Competitive Grants Program	$157,597
10.221	Tribal Colleges Education Equity Grants	$109,589
10.527	New Beginning for Tribal Students	$82,373
93.859	Biomedical Research and Research Training	$37,505
47.076	Stem Education (formerly Education and Human Resources)	$26,955
10.227	1994 Institutions Research Grants	$18,309
12.598	Centers for Academic Excellence	$13,134
84.007	Federal Supplemental Educational Opportunity Grants	$7,434
45.311	Native American and Native Hawaiian Library Services	$4,510