Finding 570432 (2023-008)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2025-07-02
Audit: 361393
Organization: College of Micronesia - Fsm (FM)
Auditor: Ernst & Young

AI Summary

  • Core Issue: The College is not updating student enrollment information in the NSLDS, leading to noncompliance with federal reporting requirements.
  • Impacted Requirements: Enrollment data for 60% of tested students lacks accurate campus-level and program-level information.
  • Recommended Follow-Up: Implement a formal process for monitoring updates, establish internal controls, conduct periodic reviews, and train staff on compliance procedures.

Finding Text

Finding No.: 2023-008 Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Enrollment Reporting Questioned Costs: $--- Criteria: Institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two , both of which need to be reported accurately and have separate record types. Condition: For 24 (or 60%) of 40 students tested, campus level information is not updated in NSLDS. Campus-level record data elements include OPEID number, enrollment effective date, enrollment status and certification date. For 21 (or 53%) 40 students tested, program level information is not updated in NSLDS. Program- level record data elements include OPEID number, Classification of Instructional Programs (CIP) code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status, program enrollment effective date. Cause: The non-compliance is due to inadequate processes and controls for monitoring and updating students' enrollment status in the NSLDS. This includes delays in processing updates and a lack of oversight to ensure accurate reporting. Effect: The College is in noncompliance with applicable enrollment reporting requirements. Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Corrective Action Plan

Finding No.: 2023-008 Recommendation The College acknowledges the finding and is committed to addressing the gaps identified in enrollment reporting to the National Student Loan Data System (NSLDS). We recognize that accurate and timely reporting at both the Campus Level and Program Level is critical to maintaining compliance with U.S. Department of Education Title IV requirements and ensuring that students’ federal financial aid records are correctly reflected. Response 1. The College will retain the FAO as the lead unit responsible for NSLDS enrollment reporting, in alignment with Title IV compliance functions. However, the College will strengthen interdepartmental collaboration by establishing a formal partnership with the Registrar’s Office, which maintains the official record of enrollment data. 2. A shared workflow and communication protocol between the FAO and Registrar’s Office will be developed to ensure timely, accurate updates of both campus-level and program-level data. The Registrar’s Office will be responsible for updating student enrollment data, which serves as the source data for NSLDS reporting. The FAO will extract and upload these reports via the Enrollment Reporting Roster (ERR) on the NSLDS Professional Access portal. 3. The College will implement internal controls to track and verify changes in student enrollment status, program information, and key data elements. These controls will include but by no means limited to: a. A monthly reconciliation process between SIS data and NSLDS records. b. Use of exception reports to flag and resolve inconsistencies or delays. c. Documentation of all update logs for audit purposes. Periodic reviews will be conducted at least once per term to assess the accuracy and completeness of enrollment reporting. Any discrepancies will be promptly addressed and procedures updated as necessary to prevent recurrence. Relevant staff in both the FAO and Registrar’s Office will receive regular training on NSLDS reporting requirements, including proper use of record types (Campus vs. Program Level), enrollment status codes, and certification timelines. Training will emphasize the implications of noncompliance and best practices for accurate reporting. Training logs will be maintained by both the FAO and Registrar’s Office to support accountability and audit-readiness. Contact: VPEMSS Completion Date: September 30, 2025

Categories

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

Other Findings in this Audit

  • 570428 2023-004
    Significant Deficiency
  • 570429 2023-005
    Significant Deficiency
  • 570430 2023-006
    Material Weakness
  • 570431 2023-007
    Material Weakness
  • 570433 2023-009
    Significant Deficiency
  • 570434 2023-009
    Significant Deficiency
  • 570435 2023-009
    Significant Deficiency
  • 570436 2023-009
    Significant Deficiency
  • 570437 2023-009
    Significant Deficiency
  • 1146870 2023-004
    Significant Deficiency
  • 1146871 2023-005
    Significant Deficiency
  • 1146872 2023-006
    Material Weakness
  • 1146873 2023-007
    Material Weakness
  • 1146874 2023-008
    Material Weakness
  • 1146875 2023-009
    Significant Deficiency
  • 1146876 2023-009
    Significant Deficiency
  • 1146877 2023-009
    Significant Deficiency
  • 1146878 2023-009
    Significant Deficiency
  • 1146879 2023-009
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $9.33M
84.425 Education Stabilization Fund $1.26M
10.511 Smith-Lever Extension Funding $772,212
15.875 Economic, Social, and Political Development of the Territories $671,227
84.047 Trio Upward Bound $596,043
11.307 Economic Adjustment Assistance $424,597
11.028 Connecting Minority Communities Pilot Program $341,775
84.044 Trio Talent Search $340,205
93.236 Grants to States to Support Oral Health Workforce Activities $289,130
10.203 Payments to Agricultural Experiment Stations Under the Hatch Act $190,567
10.322 Distance Education Grants for Institutions of Higher Education in Insular Areas $83,237
10.514 Expanded Food and Nutrition Education Program $56,096
10.308 Resident Instruction, Agriculture, and Food Science Facilities and Equipment Grants $43,325
47.076 Stem Education (formerly Education and Human Resources) $26,110