EIN: 410694747
UEI: KALKKJL418Q7
Audited by: CliftonLarsonAllen 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 February 17, 2026. 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 August 17, 2026 (13 days ago).
What is a management decision? →During our testing, we noted that 5 out of the 60 selections did not have the correct enrollment effective date entered to NSLDS, 8 of the 60 did not have the correct status reported timely, and 1 of the 60 did not have regular updates in the required intervals. Questioned Costs: None Context: There were instances of miscommunication internally at Carleton and with NSC that caused these errors and reporting errors due to a new system change. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause the students to not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted that 5 out of the 60 selections did not have the correct enrollment effective date entered to NSLDS, 8 of the 60 did not have the correct status reported timely, and 1 of the 60 did not have regular updates in the required intervals. Questioned Costs: None Context: There were instances of miscommunication internally at Carleton and with NSC that caused these errors and reporting errors due to a new system change. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause the students to not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We identified that the issue is related to transferring data between NSC (where we report enrollment for all students) and NSLDS (where federal aid recipients are monitored). To bridge this gap, we have provided a member of the Registrar’s Office with access to NSLDS to audit the data submitted to NSC and the transfer of information. Additionally, we are conducting research to determine if there are alternative reporting options that may provide greater accuracy. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: March 2026
2024-001
We noted that 1 out of the 8 selections did not have the correct calculation of their R2T4 amount causing an error in funds required to return. Questioned Costs: $113 Context: There were instances of issues with an automatic calculation and no proper review was performed. Cause: The College’s processes and controls did not ensure that student's return was calculated properly due to a system error. The College has review in place, but reviewer did not catch issue. Effect: The calculation of what needs to be returned is not proper. Repeat Finding: No Recommendation: We recommend the Institute review all calculations to confirm accuracy. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, requires calculations of Title IV aid for all students who have withdrawn or declared a Leave of Absence during the middle of a school period where aid was received. Condition: We noted that 1 out of the 8 selections did not have the correct calculation of their R2T4 amount causing an error in funds required to return. Questioned Costs: $113 Context: There were instances of issues with an automatic calculation and no proper review was performed. Cause: The College’s processes and controls did not ensure that student's return was calculated properly due to a system error. The College has review in place, but reviewer did not catch issue. Effect: The calculation of what needs to be returned is not proper. Repeat Finding: No Recommendation: We recommend the Institute review all calculations to confirm accuracy. Views of Responsible Officials: There is no disagreement with the audit finding.
Title: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review all R2T4 calculations to confirm accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We added an additional validation step in our process to confirm that the original charge amounts are accurate. Name(s) of the contact person(s) responsible for corrective action: Danielle Hayden Planned completion date for corrective action plan: October 1, 2025
FAC accepted this audit on October 29, 2024 — management decision was due April 29, 2025.
We noted that 4 out of the 40 selections did not have the correct enrollment effective date entered to NSLDS, 1 of the 40 did not have the correct status, 1 of the 40 was not updated within the required time frame, and 1 of the 40 did not have agreeing enrollment effective dates between the Campus and Program Records. Questioned Costs: None reported Context: There were instances of miscommunication internally at Carleton and with NSC that caused these errors. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause the students to not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.033, 84.007, 84.063 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: We noted that 4 out of the 40 selections did not have the correct enrollment effective date entered to NSLDS, 1 of the 40 did not have the correct status, 1 of the 40 was not updated within the required time frame, and 1 of the 40 did not have agreeing enrollment effective dates between the Campus and Program Records. Questioned Costs: None reported Context: There were instances of miscommunication internally at Carleton and with NSC that caused these errors. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause the students to not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.033, 84.007, 84.063 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Other matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: We noted that 4 out of the 40 selections did not have the correct enrollment effective date entered to NSLDS, 1 of the 40 did not have the correct status, 1 of the 40 was not updated within the required time frame, and 1 of the 40 did not have agreeing enrollment effective dates between the Campus and Program Records. Questioned Costs: None reported Context: There were instances of miscommunication internally at Carleton and with NSC that caused these errors. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause the students to not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.033, 84.007, 84.063 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: We noted that 4 out of the 40 selections did not have the correct enrollment effective date entered to NSLDS, 1 of the 40 did not have the correct status, 1 of the 40 was not updated within the required time frame, and 1 of the 40 did not have agreeing enrollment effective dates between the Campus and Program Records. Questioned Costs: None reported Context: There were instances of miscommunication internally at Carleton and with NSC that caused these errors. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause the students to not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Last year, we developed additional validation steps to ensure that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and NSLDS. These validation steps improved the accuracy of reporting for students included in the bulk reporting process. I will conduct a comprehensive review of our current reporting procedures to identify any gaps or inefficiencies. An additional staff member will be trained to report individual students to the National Student Clearinghouse in a timely manner, ensuring that any "one-off" updates are promptly completed. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: October 1, 2024
2023-001
During our testing, we noted 2 of the 20 disbursements tested had incorrect Pell disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None reported Context: The College did not have an official policy outlining the steps for updating these dates and turnover in the department that handles this reporting. Cause: The College does not have an official policy in place to ensure that dates entered are correct. Effect: The College is not in compliance with Department of Education regulations. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Other matter Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 2 of the 20 disbursements tested had incorrect Pell disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None reported Context: The College did not have an official policy outlining the steps for updating these dates and turnover in the department that handles this reporting. Cause: The College does not have an official policy in place to ensure that dates entered are correct. Effect: The College is not in compliance with Department of Education regulations. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Title: Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our office will create formal procedures for the Pell origination/disbursement process to ensure that our dates within the system and COD are aligned. Additionally, our new financial aid management system (FAMS) has the ability to track discrepant dates between COD and our FAMS and we will regularly use this feature to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Danielle Hayden Planned completion date for corrective action plan: November 1, 2024
FAC accepted this audit on December 12, 2023 — management decision was due June 12, 2024.
We noted that 2 out of 40 students tested did not have their enrollment status timely updated from full time to graduate in NSLDS. Questioned Costs: None reported Context: There was a miscommunication between Carleton and the National Student Clearinghouse as to the status of these students that were marked as complete. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause the students to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.033, 84.007, 84.063 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: We noted that 2 out of 40 students tested did not have their enrollment status timely updated from full time to graduate in NSLDS. Questioned Costs: None reported Context: There was a miscommunication between Carleton and the National Student Clearinghouse as to the status of these students that were marked as complete. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause the students to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Department of Education Carleton College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 – June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have developed additional validation steps to confirm that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and at NSLDS. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: 9/30/2023 If the Department of Education has questions regarding this plan, please call Theresa Rodriguez, Registar at 507-222-4290.
FAC accepted this audit on November 4, 2022 — management decision was due May 4, 2023.
FAC accepted this audit on March 1, 2022 — management decision was due September 1, 2022.
FAC accepted this audit on March 7, 2021 — management decision was due September 7, 2021.
FAC accepted this audit on October 21, 2019 — management decision was due April 21, 2020.
FAC accepted this audit on October 21, 2018 — management decision was due April 21, 2019.
FAC accepted this audit on November 9, 2017 — management decision was due May 9, 2018.
FAC accepted this audit on October 19, 2016 — management decision was due April 19, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
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