Finding Text
2022 ? 004 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: E-P268K90313, grants were awarded within the 2020-21 and 2021-22 award years. Award Period: September 1, 2021, through August 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). The College should establish and maintain effective internal control over the Federal award that provides reasonable assurance that the College is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: N/A Context: 1.) During our testing of NSLDS Enrollment Reporting, we noted status change were received by NSLDS outside the 60-day timeframe for 10 out of the 40 students sampled. 2.) During our testing of enrollment status reporting, 2 of the 40 student tested for the 2021-22 award year had incorrect enrollment effective dates reported to NSLDS. Cause: The College policies and procedures did not ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Yes - Finding 2021-004 Recommendation: The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College?s last date of attendance. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.