Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P222871, P268K23871
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement:
Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the
terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework”, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance:
1. The Code of Federal Regulations, 34 CFR 685.309(b), states that:
Colleges must have some arrangement to report student enrollment data to the National
Student Loan Data System (NSLDS) through an enrollment roster file. The college 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 college must report accurately the enrollment status of all students
regardless if they receive aid from the institution or not.
Colleges must have some arrangement to report student program enrollment effective date
and status to NSLDS.
2. Per Section 4.4.8 of the NSLDS Enrollment Reporting Guide, the Program Begin Date is the
date the student fist began attending the program being reported. Typically, this would be the
first day of the term in which the student began enrollment in the program.
3. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2),
requires that enrollment status changes for students be reported to NSLDS within 30 days or
within 60 days if the student with the status change will be reported on a scheduled
transmission within 60 days of the change in status. Additionally, schools are required to certify
enrollment at a minimum of every 60 days or every other month.
Condition: Incorrect enrollment status, effective date, and program begin date were reported to
NSLDS. It was also noted that the change in status was not reported timely.
Questioned costs: None
Context: This condition occurred in our statistically valid sample as follows:
1. The Enrollment Status was incorrectly reported for 24 out of 40 students.
2. The Effective Date was incorrectly reported for 9 out of 40 students.
3. The begin date was incorrectly reported for 26 out of 40 students.
4. The status was not reported timely for 9 out of 40 students.
Cause:
1. Montgomery College utilizes the National Student Clearinghouse (NSC) as a third-party
provider in order to submit student information to the NSLDS. Student enrollment status
corrections were uploaded to NSC timely, however, monitoring of the upload through success
was inconsistent, resulting in error reports preventing the accurate and timely update to the
enrollment statuses. No review was completed to ensure the upload was completed in NSLDS.
2. Inaccurate Student withdrawal effective dates were not identified timely due to delays in the
review of student withdrawal status.
3. Inaccurate Student program begin dates were due to a programming issue with the file
transmission software. Program start date was updating each semester to the latest semester
start date. There was insufficient review to identify the problem and recommend a solution to
resolve.
Effect: Student enrollment status, effective date, and program begin date was not reported accurately
to NSLDS.
Repeat finding: No
Recommendation: The College should evaluate their procedures and policies related to reporting
status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is
reported to NSLDS.
Views of responsible officials: There is no disagreement with the audit finding.