Finding Text
Federal agency: Department of Education
Federal program title: Federal Pell Grant Program, Federal Direct Loan Program
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P221554 and P268K231554
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters (Nonmaterial
Noncompliance)
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: Per the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, schools
are required to report enrollment and the Program-Level in addition to the Campus-Level. Included in this
required reporting is an Enrollment status for each program which a student is enrolled. The Code of
Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to
the National Student Loan Data System (NSLDS). Regulations require the status include an accurate
effective date.
Condition: The enrollment status of graduation for two students was not updated to NSLDS from the
correct withdrawn status.
Questioned costs: None
Context: This condition occurred for 2 out of 22 students selected for testing.
Cause: These two students stop attending in the Fall 2022 semester. At that time, the two students were
reported correctly to NSC and NSLDS with an enrollment status as withdrawn from institution with the end
of fall semester date. Subsequently, both students graduated in Spring 2023. As part of the College’s
normal end-of-term business practice, the College supplies a graduation file to NSC. The graduation file
lists all students who graduated for the term. The graduation file for Spring 2023 supplied to NSC properly
included these two students. Unfortunately, NSC does not automatically update a student’s status if the
student has been away from the College for more than 120 days. These two students fell within that
window since their last day of attendance was during the Fall 2022 semester. When NSC uploaded the
spring graduation file to NSLDS, these two students were marked as grad not applied due to both students
being in a withdrawn status for over 120 days. Moving forward, the College will add an additional step to
the reporting business process and manually update students who have graduated, but have not been
enrolled for more than 120 days.
Effect: Enrollment status was not updated properly to NSLDS.
Repeat Finding: No
Recommendation: We recommend the College review its reporting procedures to ensure that students’
statuses and enrollment information are correctly and timely reported to NSLDS as required by
regulations.
Views of responsible officials: There is no disagreement with the audit finding.