TRINITY COLLEGE

Criteria The U.S. Department of Education has implemented National Student Loan Data System (NSLDS) Enrollment Reporting requirements through specific regulations in the Direct Loan and Pell Programs at 34 CFR 685.309(b), 690.83(b)(2), respectively. At a minimum, schools are required to fully and accurately respond to Enrollment Reporting Roster files for Title IV aid recipients within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer, correct any errors within 10 days, and certify enrollment data at least every 60-days. Condition We selected 25 students for testing of the accuracy and timeliness of the student?s status change report and noted, for one selection, the student?s change in program-level enrollment was not reported accurately to NSLDS. Further, per inquiry with the College?s Registrar, nine additional students had an inaccurate program-level status change reported. The College updates each student?s campus and program-level enrollment status through the Clearinghouse website, which then transmits the data to NSLDS. Although the College met the accuracy and timeliness requirement for campus-level enrollment status, the College did not accurately report the student?s program-level status change. Cause The College understands this specific circumstance may arise when a manual update is made by the College on the Clearinghouse website to mark a withdrawn student as graduated. The Clearinghouse only updates the record at the campus level rather than both the campus-level, program-level, and it is the College?s responsibility to manually update the program level status in NSLDS. It was noted that the manual graduation updates are required for Summer and Fall graduates. For the selection identified, when the Fall graduate data from the Clearinghouse was pushed to NSLDS via a manual update, only the campus level record was updated, and the program-level status was not updated by the College to reflect the student?s graduation date in a timely manner. Effect The student?s program-level enrollment status was not accurately reported to the NSLDS. Questioned Costs There are no questioned costs as the finding pertains to the transfer of information. Recommendation We recommend that the Trinity College review all manual updates to the Clearinghouse website for Spring, Summer, and Fall graduates to ensure the campus level status is updated to NSLDS accurately and timely, and manually update the program level status as needed within NSLDS accurately and in a timely manner. Views of Responsible Officials and Planned Corrective Action Plan Refer to management?s Corrective Action Plan.

Student Financial Aid Cluster ? Federal Pell Grant Program ? CFDA #84.063 ? Federal Direct Student Loan Program Loans- CFDA #84.268 Award Year: 07/01/2018 ? 06/30/2019 Criteria The Office of Management and Budget has implemented compliance requirements through specific regulations related to Borrower Data Transmission and Reconciliation (OMB No. 1845-0021). Institutions must report all loan disbursements and submit required records to Common Origination Disbursement site (?COD?) within 15 days of disbursement. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Condition We selected 37 students for testing the timeliness of the student?s loan disbursement and noted, for twenty eight selections, the student?s loan disbursement was not reported timely (within 15 days) to COD. Cause College believes that it is possible that issues with the Common Origination Disbursement site may have caused the delayed submission of the Pell and Direct Loan disbursements to COD. This resulted in disbursements not being submitted within the 15 day required period. Effect The Pell and Direct Loan disbursement was not reported to COD timely. Questioned Costs There are no questioned costs as the finding pertains to the transfer of information. Recommendation We recommend that the Trinity College review loan disbursement information to ensure that it is reported to COD within the 15 day requirement. Views of Responsible Officials and Planned Corrective Action Plan The Financial Aid Office, which is responsible for loan disbursements, will implement a tracking system to ensure that all Pell and Direct Loan disbursements will be submitted to COD within the required reporting period. Each time Pell Grant and Direct Loan records are disbursed to the student accounts, an entry will be posted noting the due date for the file on the shared Outlook calendar. The entry will indicate that the specific Pell and Direct Loan disbursement file must be submitted to COD before a specified date. The Director and responsible staff will be able to verify that the submission has taken place when the reminders appear. Contact: Carol Kessel, Associate Comptroller carol.kessel@trincoll.edu 860-297-2032

GSA_MIGRATION