Finding Text
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.