EIN: 042104847
UEI: JVZEJJ6N5EM8
Audited by: PRICEWATERHOUSECOOPERS, LLP
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 31, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 31, 2025 (393 days ago).
What is a management decision? →Through testing a sample of 10 students selected for verification, we identified 1 student whose verification status was not appropriately coded in the COD system and 2 students who did not have the correct number of family members enrolled in eligible postsecondary institutions in the FAFSA compared to the verification worksheet. Cause: The College performs a manual review process over verification and these items were missed in the manual review. Effect or Potential Effect: Incorrect information included in the FAFSA could impact the amount of federal aid provided to the student. None of the exceptions noted affected the amount of aid provided to the sampled students. Questioned Costs (if applicable): Not applicable. Recommendation: We recommend the College provide additional training and ensure those performing the manual reviews over verification understand the importance of accurate reporting. Views of Responsible Officials: See Management’s View and Corrective Action Plan included in this report.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 668.54, “an institution must require an applicant whose Free Application Federal Student Aid (FAFSA) information is selected for verification by the Secretary, to verify the information specified by the Secretary.” Per 34 CFR 668.57, “if an applicant is selected to verify any of the following information, an institution must obtain the following specified documentation (a) Adjusted Gross Income (AGI), income earned from work, or U.S. income tax paid, (b) Number of family members in household, and (c) Number of family household members enrolled in eligible postsecondary institutions.” Additionally, for students who received Pell grants the student's verification status code must be entered in the Common Origination and Disbursements (COD) system. Condition: Through testing a sample of 10 students selected for verification, we identified 1 student whose verification status was not appropriately coded in the COD system and 2 students who did not have the correct number of family members enrolled in eligible postsecondary institutions in the FAFSA compared to the verification worksheet. Cause: The College performs a manual review process over verification and these items were missed in the manual review. Effect or Potential Effect: Incorrect information included in the FAFSA could impact the amount of federal aid provided to the student. None of the exceptions noted affected the amount of aid provided to the sampled students. Questioned Costs (if applicable): Not applicable. Recommendation: We recommend the College provide additional training and ensure those performing the manual reviews over verification understand the importance of accurate reporting. Views of Responsible Officials: See Management’s View and Corrective Action Plan included in this report.
Management agrees with the finding and in concurrence with the recommendations we have reviewed the federal verification definitions, and the importance of selecting the correct verification status in the COD system, with staff who participate in the federal verification process to ensure they understand the federal definition of number of family members in college. Ongoing training will be provided and a senior member of our staff will audit the verification process moving forward. This corrective action plan has been implemented as of January 2025.
We reviewed a sample of 15 students enrolled at the College who received either Pell and/or Direct Loans and had a change of enrollment status during the fiscal year. Of the 15 students tested, we identified 1 student whose program level status was certified with an incorrect effective date, however, was reported within the required 60-day timeframe. Cause: The student was originally enrolled in two majors at the program level at the College. The College was notified in December that the student withdrew from the College with a last date of attendance (effective date) in October. However, in November, the student dropped one of its majors. Given the change in majors, the effective date at the program level for the major that the student maintained was inaccurately updated to November. Effect or Potential Effect: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by inaccurate and late reporting. The student’s campus level status was certified correctly. Questioned Costs (if applicable): Not applicable. Recommendation: We recommend the College review its procedures and controls to ensure accurate and timely enrollment reporting. Views of Responsible Officials: See Management’s View and Corrective Action Plan included in this report
Show full finding ▾Hide full finding ▴Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, the College is required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through National Student Loan Data System (NSLDS). The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the College in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student that received a Direct Loan and was enrolled or accepted for enrollment at the College, and the student had ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, the College must report the change within 60 days from which the change was identified. Condition: We reviewed a sample of 15 students enrolled at the College who received either Pell and/or Direct Loans and had a change of enrollment status during the fiscal year. Of the 15 students tested, we identified 1 student whose program level status was certified with an incorrect effective date, however, was reported within the required 60-day timeframe. Cause: The student was originally enrolled in two majors at the program level at the College. The College was notified in December that the student withdrew from the College with a last date of attendance (effective date) in October. However, in November, the student dropped one of its majors. Given the change in majors, the effective date at the program level for the major that the student maintained was inaccurately updated to November. Effect or Potential Effect: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by inaccurate and late reporting. The student’s campus level status was certified correctly. Questioned Costs (if applicable): Not applicable. Recommendation: We recommend the College review its procedures and controls to ensure accurate and timely enrollment reporting. Views of Responsible Officials: See Management’s View and Corrective Action Plan included in this report
Management agrees with the finding and in concurrence with the recommendations the Registrar’s Office processes and documentation will be updated as follows: Major change process: If a request is submitted to drop a major while a student is on leave, the effective date will be recorded as the date of the leave rather than the date the change was initiated. Leave of absence process: All withdrawals will be reported to the National Student Clearinghouse (NSC) manually within 2 weeks of being processed to avoid any delays or issues with the regularly scheduled Peoplesoft delivered report. If due to the schedule, a W status is reported via the delivered report instead of by hand, the person responsible for enrollment reporting will verify the status with the NSC, including program-level data. Ongoing training will be provided and a senior member of our staff will audit the major change and leave of absence processes moving forward. This corrective action plan has been implemented as of January 2025.
FAC accepted this audit on March 23, 2023 — management decision was due September 23, 2023.
We tested a sample of seventeen students enrolled at Williams College who received either Pell and/or Direct Loans and had a change of enrollment status during the fiscal year. Of the seventeen students tested, two students met the requirements for graduation in December 2021 and their enrollment status was not accurately reported to the NSLDS until March 2022. Questioned Costs: None Cause: Williams College utilizes the National Student Clearinghouse (?NSC?) to submit enrollment information to NSLDS. Once a student has a change in enrollment, Williams College updates the enrollment information in its student information system. For graduates, an automated student information system process generates a report at the completion of each semester that is uploaded to the NSC to report the change in enrollment to the NSLDS. These students, who had extended their enrollment due to the pandemic, completed their degree requirements in December, and were not included in the process as their degree was not conferred by Williams College until June 2022. There was no manual process in place to validate that those students who completed their degree after the automated report was generated were reported to NSC or NSLDS. The change in enrollment for these two students was reported in March when the subsequent process had been completed for the spring semester, and again when degrees were conferred in June. Effect: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies, all of which are impacted by inaccurate and late reporting. Recommendation: We recommend Williams College include a manual process to validate all student enrollment changes were appropriately submitted to the NSC accurately and timely. Management?s Response: Management?s Views and Corrective Action Plan is included at the end of this report after the summary schedule of prior audit findings and status.
Show full finding ▾Hide full finding ▴Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/21 ? 6/30/22 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant (?Pell?) and Federal Direct Loan (?Direct Loan?) programs through the National Student Loan Data System (?NSLDS?). The enrollment information, including Campus Level and Program Level data, must be reviewed, updated, and validated by the institution promptly. Furthermore, specific to the Direct Loan program, for a student that received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, the institution must report the change within 60 days from which the change was identified. Condition: We tested a sample of seventeen students enrolled at Williams College who received either Pell and/or Direct Loans and had a change of enrollment status during the fiscal year. Of the seventeen students tested, two students met the requirements for graduation in December 2021 and their enrollment status was not accurately reported to the NSLDS until March 2022. Questioned Costs: None Cause: Williams College utilizes the National Student Clearinghouse (?NSC?) to submit enrollment information to NSLDS. Once a student has a change in enrollment, Williams College updates the enrollment information in its student information system. For graduates, an automated student information system process generates a report at the completion of each semester that is uploaded to the NSC to report the change in enrollment to the NSLDS. These students, who had extended their enrollment due to the pandemic, completed their degree requirements in December, and were not included in the process as their degree was not conferred by Williams College until June 2022. There was no manual process in place to validate that those students who completed their degree after the automated report was generated were reported to NSC or NSLDS. The change in enrollment for these two students was reported in March when the subsequent process had been completed for the spring semester, and again when degrees were conferred in June. Effect: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies, all of which are impacted by inaccurate and late reporting. Recommendation: We recommend Williams College include a manual process to validate all student enrollment changes were appropriately submitted to the NSC accurately and timely. Management?s Response: Management?s Views and Corrective Action Plan is included at the end of this report after the summary schedule of prior audit findings and status.
Management's View and Corrective Action Plan Finding 2022-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS): Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2021 - 6/30/2022 Assistance Listing Numbers: 84.063 and 84.268 Management agrees with the finding and in concurrence with the recommendations has developed the following corrective action plan: The Registrar?s Office will manually reconcile enrollment status after each submission to the National Student Clearinghouse (?NSC?) submission to ensure student enrollment changes are submitted completely and timely. Alan Hatton, the Senior Associate Registrar, is responsible and has implemented this corrective action plan in February of 2023. Signed and Acknowledged, Kath Dunlop, Registrar
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