Finding Text
2022-005: Special Tests & Provisions – Enrollment Reporting
Federal Agency:
Department of Education
Federal Program Title:
Student Financial Aid Cluster
Assistance Listing Number:
84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A215801 (March 25, 2021 - August 31, 2027),
P033A215801(July 1, 2021 - August 31, 2027),
P063P213807(March 23, 2021 - August 31, 2027),
P268K223807(January 1, 2021 - July 31, 2043)
Award Period:
July 1, 2021 – June 30, 2022
Type of Finding: Significant Deficiency 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- The Code of Federal Regulations, 34CFR section 682.610 states that all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a Roster file. Rosters must be returned within 15 days and any subsequent error records must be returned within 10 days.
Condition: The University’s June 2022 roster was not returned within 15 days of receipt. The University did not maintain reporting records for 13 of 38 students selected for testing. It was noted that 1 of the 38 students' enrollment status per institution records and NSLDS did not agree.
Questioned Costs: None
Context: While the University is reporting enrollment to the Clearinghouse each month, the June enrollment roster was not returned within the required 15-day period. While the University is reporting enrollment changes, it does not have adequate policies and procedure to ensure documentation for reporting is accurately reported and retained.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures to ensure accurate, timely, and complete enrollment reporting.
Effect: National Student Loan Database System (NSLDS) is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: Yes – 2021-003.
Recommendation: We recommend that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and within the required time period.
Views of Responsible Officials: There is no disagreement with the audit finding.