Finding Text
2023-004 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls
over Compliance and Material Noncompliance
Student Financial Assistance Cluster
Department of Education
Federal Assistance Listing Number: 84.063, 84.268
Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized
database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family
Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure
attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance
change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately
as outlined in 34 CFR § 685.309.
Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level
Record and Program-Level Record that ED considers high risk, which includes the student's program as per the
Classification of Instructional Programs (CIP) code, and the student's status change Effective Date.
Condition/context – The College did not report enrollment status changes to NSLDS during the 2022-2023 award
year.
Questioned costs – None reported.
Cause/effect – The College did not have controls in place to ensure the reporting of enrollment information under
the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls
the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been
working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award
year and has not resumed. Management did not implement other processes or procedures to deal with the issues
encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission
of student status during the year. The College is not in compliance with the federal enrollment reporting
requirements described in the OMB Compliance Supplement and required by the Department of Education.
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Repeat finding – Yes, 2022-003
Recommendation – The College should implement a process to review, update, and verify 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, regardless of whether or not it has to be done manually in situations where the
software is not reporting correctly. Management should immediately go through all students that
were awarded funds under these programs to ensure their status and all relevant student data is correct on
NSLDS.
Views of responsible officials and planned corrective actions –
Responsible Individuals: Mary Martin, Registrar
Michael N. Espinoza, Vice President of Student Services
Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College
(CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was
impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included
significant changes to student recording procedures and a new enrollment reporting process.
In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues
working to mitigate any issues negatively impacting enrollment reporting by:
working with the Vice President of Student Services and Director of Financial Aid to establish internal checks
and balances to ensure reporting is being done in a timely manner.
working with SIS system support staff and internal IT staff to promptly address technical issues and/or other
issues impacting enrollment reporting.
working with National Student Clearinghouse representative to ensure reporting schedule meets required
timeframes.
consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and
program information are being reported.
prompt resolution of reporting errors.
identifying and training of additional staff on enrollment reporting.
Anticipated Completion Date: to be completed by June 30, 2024