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FINDING 2022-003 ? Special Tests and Provisions - Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2021-22 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information. It is the College?s responsibility to update this information timely and accurately. Effective January 12, 2023; NSLDS has published issues with the enrollment reporting website, affecting submissions from July 19, 2022 to February 28, 2023, thus those have been removed from the condition and context section. The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. The College has engaged the National Student Clearinghouse's (NSC) services to assist with the reporting of student's status changes and degrees to the NSLDS. Condition and context: In our audit sample of 25 items, which included 12 withdrawals and 13 graduated students, 11 status changes were reported late to NSLDS. Our sample was selected using a random sampling methodology, from a population of 104 withdrawals, and 174 graduates. Subsequently, the withdrawn or graduated student status was corrected for the sampled students, but not within the required timeframe. Questioned costs: None Effect: This information is utilized by ED, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. American Samoa Community College doesn?t participate in loan programs, which limits the effect of non-compliance. Cause: This occurred because of a lack of control in place to monitor for compliance. Repeat finding: Yes, 2021-003. Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. Furthermore, we recommend the College educate staff involved in the process regarding the Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC. This policy should specifically address the personnel assigned to various tasks (data entry and review). Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the College establish an internal monitoring control whereby a designated individual with NSLDS access, spot-checks the status updates on NSLDS on a sample basis so as to internally audit the submissions. Views of responsible officials and planned corrective actions: NSLDS Plan and Corrective Actions: The Financial Aid Coordinator (control #1, with FA Officer as alternate) has been assigned to transmit the bi-monthly Enrollment Report roster. The control #1 reviews the roster and performs data entry, status updates and submission by the 15th of the reporting month. On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th. Counselor III (control #2) is assigned to monitor and spot check the status updates on NSLDS after the 25th of every month to internally audit the submissions. The policy will ensure all student changes in status are identified, updated and submitted timely and accurately. ASCC FAO participates in Federal Student Aid (FSA) training and conferences regarding NSLDS updates, changes and functionality. FAO also subscribes to the Weekly Knowledge Center Updates from FSA Partner Connect. ASCC is a member of the National Association of Student Financial Aid Administrators (NASFAA). All of these resources provide access and education in the process of enrollment reporting and compliance, as well as responsibilities and consequences of inaccurate reporting. Controls (#1 and #2) shall be included accordingly in the job descriptions of the Financial Aid Coordinator and Counselor III as well as the Financial Aid Standard Operating Procedures for consistency in compliance and reporting. Graduates: Students who graduate will be updated into NSLDS within one week after graduation. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days. Anticipated completion of the corrective action is expected by June 2023.