Finding Text
Criteria or specific requirement: 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).
Institutions are required to report enrollment status information of students under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment status information reported by institutions to NSLDS. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level, both of which need to be reported accurately and have separate record types. At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Condition: There were instances in which the College did not report status changes timely.
Questioned costs: None.
Context: In our statistically valid sample of 40 students selected for NSLDS enrollment reporting testing, we identified that status change for 34 selections was not reported timely nor was their enrollment certified every 60 days.
Cause: Colorado Mountain College did not have proper procedures in place to ensure NSLDS enrollment reporting was proper and timely.
Effect: Failure to properly and timely report enrollment status changes on NSLDS impacts the Department of Education’s ability to administer Title IV programs.
Repeat finding: No.
Recommendation: We recommend that the College work with their third-party servicer and implement procedures and internal controls to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely.
Views of responsible officials: There is no disagreement with the audit finding.