Northeastern Essex Community College

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 10 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with enrollment status changes were reported to NSLDS within the required timeframe. The College uses the National Student Clearinghouse (“NSC”) to process student enrollment change submissions to NSLDS. There were discrepancies on the roster file submitted by the College to NSC in January 2024, which caused a delay in the enrollment changes from that file being processed and submitted to NSLDS. The delay in January 2024 also resulted in a delay to subsequent enrollment roster files submitted because roster files are processed in order of their certification dates. These subsequent delays caused several enrollment status changes to submitted late to NSLDS, which is ultimately the responsibility of the College. Effect The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 25% of our sample, had status changes that were not reported to NSLDS within the required timeframe. The 10 students were submitted between 6 and 209 days late. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters and routine review of enrollment reporting submissions may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2024 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 9, where the aid returned was different than the amount correctly calculated on the Return to Title IV (“R2T4”) form. Cause The College did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. While the college correctly calculated the student’s earned and unearned amounts, the College debited the student’s account in amount of $1,943, which represented the amount earned by student. The debit to the student’s account should have been $1,769, representing the amount to return to the Department of Education per the R2T4 form. This resulted in an under awarding of aid that the student earned. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $174 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 1 student, or 11% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Federal Work-Study (“FWS”) Assistance Listing #: 84.033 Award year: 2024-003 Criteria According to 34 CFR 675.19(a): The institution must establish and maintain program and fiscal records that include a certification by the student's supervisor, an official of the institution, or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for the students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. The 2023-2024 Federal Student Aid Handbook (Vol. 6, Pg. 33) states: In general, students are not permitted to work in Federal Work-Study positions during scheduled class times. Exceptions are permitted if the individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work- study experience. Any such exemptions must be documented. Condition Federal regulations require an institution to monitor and ensure that a work-study student is not working during his/her designated class time. Out of a sample of 3 students, we noted 2 students who worked during class time. Cause The College did not have adequate procedures in place to ensure that students did not work during class time. Effect Two students reported work-study time sheets conflicted with their respective class schedules. As a result of this scheduling conflict, the students either did not attend class or were not present during the documented time period for which they were paid Federal Work-Study wages. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 3 students selected for testing, 2 students, or 66% of our sample, were determined to have worked during class time. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that the College review, and if necessary, update the policies and procedures to ensure all Federal Work-Study supervisors are monitoring students' work time to ensure that it does not conflict with their class schedules. These policies should also be revisited and reinforced with those in charge of monitoring the students' federal work-study time. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2023 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated May 2023: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days and with an accurate effective date of the student enrollment change. During our testing, we noted 2 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS. Cause The College’s policy is to report graduated students to the NSLDS effective as of the last day of classes per the College’s academic calendar. For Fall 2022 and Spring 2023, the last day of classes was December 20, 2022 and May 8, 2023, respectively. The Registrar reported the effective date of a Fall 2022 graduate as December 31, 2022 and a Spring 2023 graduate as May 31, 2023. Effect The College did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had incorrect effective dates reported to NSLDS. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed below.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425F, 84.425L Award year: 2023 Criteria For Coronavirus Response and Relief Supplemental Appropriations Act HEERF II and American Rescue Plan Act HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education’s G5 grants system (“G5”) and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount of lost revenue after the estimation period. Condition The Federal Government requires the College to disburse the Institutional Aid Portion of HEERF funds within three calendar days of drawdown from G5. During our testing, we noted that the College drew down the entire balance of the HEERF III Institutional Aid portion and HEERF III Minority Serving Institution portion but the balances were not spent by June 30, 2023. The balances were not expended within three calendar days of drawdown as required. This is a summary of the balances unspent at June 30, 2023: Cause Due to the inexperience with the HEERF III program, the College did not have adequate procedures in place to ensure that Institutional Aid Funds and Minority Serving Institution Funds were disbursed within three calendar days of drawdown. Effect HEERF III Institutional Aid Funds and Minority Serving Institution Funds were drawn down in excess of disbursements and the excess funds remained unspent beyond the three-calendar day threshold for institutional expenditures. Due to these circumstances, the College was not in compliance with the cash management requirement of the HEERF III agreements. Questioned Costs 255,052 Perspective Our sample was not, and was not intended to be, statistically valid. We selected one HEERF institutional drawdown to test and it was not disbursed within the required three-calendar day threshold. Identification as a Repeat Finding, if applicable See finding 2022-001 included in the summary schedule of prior year findings. Recommendation We recommend that the College implements procedures to ensure that future cash drawdowns occur within the required period before or after expending the grant funds. We also recommend the College coordinate with the Department of Education to return the unspent HEERF funds with any applicable interest. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425E, 84.425F, 84.425L Award year: 2023 Criteria Question 36 of the Higher Education Emergency Relief Fund III Frequently Asked Questions required that beginning with the second quarter 2022 quarterly report (due July 10, 2022) institutions must complete and post on their websites Quarterly Reports using a new combined institutional and student reporting form. This requires that the institution detail quarterly expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition The Federal Government requires the College to accurately report quarterly expenditures and post the quarterly report to their website. During our testing, we noted that while the College properly posted their quarterly reports to their website, the expenditures per the quarterly reports did not reconcile with the institution’s underlying records. Cause Due to the inexperience with the HEERF III program and the use of temporary workers unfamiliar with the program’s requirements, the College’s underlying records did not reconcile to the expenditures on their HEERF quarterly reports. Effect The College's HEERF expenditures per the quarterly reports posted to their website were not accurate. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. We selected the four HEERF quarterly report to test and they did not reconcile to the underlying account records. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend the College create procedures to ensure College is in compliance with the program's quarterly reporting requirements. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425F Award year: 2022 Criteria For Coronavirus Response and Relief Supplemental Appropriations Act HEERF II and American Rescue Plan Act HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system (?G5?) and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. For lost revenue, the ?obligation? occurs on the date the institution completes its estimate of its amount of lost revenue after the estimation period. Condition The Federal Government requires the College to disburse the Institutional Aid Portion of HEERF funds within three calendar days of drawdown from G5. During our testing, we noted that the entire balance of the HEERF III Institutional Aid Portion was drawn down during fiscal year 2022 but none of the balance was expended within three calendar days of drawdown. Cause Due to the inexperience with the HEERF III program, the College did not have adequate procedures in place to ensure that Institutional Aid Funds were disbursed within three calendar days of drawdown. Effect HEERF III Institutional Aid Funds were drawn down in excess of disbursements and the excess funds remained unspent beyond the three-calendar day threshold for institutional expenditures. Due to these circumstances, the College was not in compliance with the cash management requirement of the HEERF III agreements. Questioned Costs $6,062,177 Perspective Our sample was not, and was not intended to be, statistically valid. We selected one HEERF institutional drawdown to test and it was not disbursed within the required three-calendar day threshold. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that the College review their excess cash and utilize that cash before drawing additional funds from the HEERF funding to ensure that there is not any additional excess cash on hand. In addition, we recommend that the College implements procedures to ensure that future cash drawdowns occur within the required period before or after expending the grant funds. View of Responsible Officials The College agrees with the finding.

Finding number: 2020-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063 and 84.268 Award year: 2020 Criteria According to 34 CFR 685.309(b)(2): Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (?ED?) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing, we noted one student, out of a sample of 40, whose status change was not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. The College's Registrar's office sent the student roster including this student's withdrawal to the National Student Clearinghouse, the service entity that processes their uploads to NSLDS, within the acceptable 60 day timeframe. The National Student Clearinghouse did not upload this student's withdrawal to the NSLDS and the College had to upload the withdrawal to NSLDS manually after the required timeframe. Effect The College did not report the student's status changes to NSLDS within the required timeframe, which may impact the student's loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, had a status change that was not reported to NSLDS until 143 days after the required timeframe. Identification as a Repeat Finding, if applicable See finding 2019-003 included in Management's Summary Schedule of Prior Audit Findings. Recommendation The College should provide training to employees responsible for processing information for the NSLDS to ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College?s date of determination of withdrawal, the importance of reporting timely and the consequences of late reporting. The College should also discuss the required processing lead times with the National Student Clearinghouse to ensure a timely upload to NSLDS. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding.

Finding number: 2019-001 Federal agency: U.S. Department of Education Programs: Federal Work-Study ("FWS") CFDA #?s: 84.033 Award year: 2019 Criteria According to 34 CFR Section 675.19(2): The institution must also establish and maintain program and fiscal records that - (i) Include a certification by the student's supervisor, an official of the institution, or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day; (ii) Include a payroll voucher containing sufficient inform to support all payroll disbursements. Condition Regulations require that the College compensate students under Federal Work-Study for the correctly calculated number of hours worked. In our testing sample of ten students who received Federal Work-Study, we noted one student whose timesheet showed that the student had worked for two hours, but the student was paid for three hours of work after miscalculating the number of hours worked during that shift. This occurred for four separate shifts over two separate pay periods for the same student receiving Federal Work-Study. A supervisor signed off on the timesheets, but the miscalculation of hours worked went unnoticed. Cause The cause was human error in calculating the number of hours worked during the shifts. The student erroneously counted three hours instead of the appropriate two hours from the start of the shift to the end of the shift for four shifts over two pay periods. The timesheet was properly reviewed by the student's supervisor but not in sufficient detail to identify the miscalculation. Effect The student was paid for more hours than actually worked. Questioned Costs The student was overpaid by a total of $48 over the four shifts. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 1 student, or 10% of our sample, had incorrect Federal Work-Study hours paid. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should examine its policies and procedures related to timesheets to ensure the correct hours worked are reported and consider using electronic timesheets for Federal Work Study payroll. Views of Responsible Officials The College agrees with the finding.

Finding number: 2019-002 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans CFDA #?s: 84.268 Award year: 2019 Criteria According to 34 CFR Section 668.165(a): (1) Before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. (2) Except in the case of a post-withdrawal disbursement made in accordance with ?668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of ? (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing ? (i) No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at the institution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section; or (ii) No earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at the institution, if the institution does not obtain affirmative confirmation from the student under paragraph (a)(6)(i) of this section. Condition Federal regulations require the College to notify students, within the required timeframe, of credits to the students' accounts of any Direct Loan. During our testing, we noted 10 students, out of a sample of 40, were not notified within the required timeframe or were not notified at all. Cause The cause was a technological error within the College's enterprise resources planning (ERP) system. Upon disbursement to students, the ERP system was supposed to automatically send a notification to the students receiving Direct Loans within the required timeframe. Due to a glitch in the system, the notifications were either never sent or sent outside of the seven-day window after disbursement to the students. Effect Students receiving Direct Loans were not notified timely that a Direct Loan had been disbursed to their student account. The College was not in compliance with notification requirements. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 25% of our sample, did not receive timely distribution notifications. Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should create a process to ensure that notifications have gone out within the required time period. Views of Responsible Officials The College agrees with the finding.

Finding number: 2019-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063 and 84.268 Award year: 2019 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (?ED?) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and ED loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing, we noted one student, out of a sample of 40, that had an incorrect effective date reported to NSLDS. Cause The College did not have adequate procedures in place to ensure that students with retroactive withdrawal status changes had their effective date correctly reported to NSLDS. Effect The College did not report the student's correct effective date to NSLDS, which may impact the student's loan grace period. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, had an incorrect effective date reported to NSLDS. Identification as a Repeat Finding, if applicable See finding 2018-001 included in the summary schedule of prior year finding. Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student?s withdrawal, the importance of reporting the correct effective date, and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College, including for retroactive withdrawals. View of Responsible Officials The College agrees with the finding.

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