Finding Text
Finding 2022-001: Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Noncompliance Criteria The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to National Student Loan Database Student (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Regulations require the status include an accurate effective date. There are two categories of enrollment information ?Campus Level? and ?Program Level? both of which need to be reported accurately. Regulations require the status include an accurate effective date. In addition, regulations require that an institution return the enrollment rosters within 15 days from receipt of the rosters and make necessary corrections and resubmit to NSLDS within 10 days. Condition Foothill College: Twenty students from a statistically valid sample identified the following conditions for 6 students: 1) The enrollment effective date reported to NSLDS did not match the College?s record - 6 students 2) The student?s enrollment status did not match the College?s Record - 1 student Condition (Continued) De Anza College: Twenty students from a statistically valid sample identified 5 students where the change in enrollment status reporting was not received by the NSLDS within the 60 days requirement. Questioned Costs None Context The Colleges disbursed $22,577,668 in Title IV awards during the year. Cause The College?s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect The case identified resulted in noncompliance with the Title IV regulation. Repeat Finding Similar conditions were noted at Foothill College and De Anza College in the 2019-20 (Finding 2020-005) and 2020-21 (Finding 2021-002). Recommendation We recommend that each College review their existing procedures and controls and identify necessary changes needed to ensure timely reporting of student status changes to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions Management concurs with the finding and has developed a plan to correct it.