Montgomery College

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P222871, P268K23871 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters 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: 1. The Code of Federal Regulations, 34 CFR 685.309(b), states that:  Colleges must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The college is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that college must report accurately the enrollment status of all students regardless if they receive aid from the institution or not.  Colleges must have some arrangement to report student program enrollment effective date and status to NSLDS. 2. Per Section 4.4.8 of the NSLDS Enrollment Reporting Guide, the Program Begin Date is the date the student fist began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program. 3. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), 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. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition: Incorrect enrollment status, effective date, and program begin date were reported to NSLDS. It was also noted that the change in status was not reported timely. Questioned costs: None Context: This condition occurred in our statistically valid sample as follows: 1. The Enrollment Status was incorrectly reported for 24 out of 40 students. 2. The Effective Date was incorrectly reported for 9 out of 40 students. 3. The begin date was incorrectly reported for 26 out of 40 students. 4. The status was not reported timely for 9 out of 40 students. Cause: 1. Montgomery College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely, however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses. No review was completed to ensure the upload was completed in NSLDS. 2. Inaccurate Student withdrawal effective dates were not identified timely due to delays in the review of student withdrawal status. 3. Inaccurate Student program begin dates were due to a programming issue with the file transmission software. Program start date was updating each semester to the latest semester start date. There was insufficient review to identify the problem and recommend a solution to resolve. Effect: Student enrollment status, effective date, and program begin date was not reported accurately to NSLDS. Repeat finding: No Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Federal regulation requires quarterly reports to be submitted related to the GEER awards. Condition: For GEER II funding, the institution was required to submit a quarterly report for the timeframe 03/01/2021 - 05/31/2021 by the due date of 06/30/2021. The institution did not submit the report until 07/19/2021, past the due date. Questioned costs: None Context: We selected two reports out of a total of four reports in the population. The finding related to the one GEER II report. Cause: The College was unaware they were required to submit a report for GEER II, as there were no funds expended for the 03/01/2021 ? 05/31/2021 timeframe. Effect: Granting agencies are not provided the required information which could impact future funding. Repeat Finding: No. Recommendation: We recommend the College review its controls and processes to ensure that reports are submitted in accordance with grantor requirements. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on their letterhead as attached.

Criteria or specific requirement: Federal regulation requires enrollment status for each student be reported accurately to NSLDS. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: National Student Loan Data System (NSLDS) rosters or roster updates yielded error records that were not corrected and resubmitted within the required 10 days. Questioned costs: None Context: We selected eight monthly transmissions to the NSLDS out of a total 36 (monthly across three campuses). This error occurred for the same one student in the months of September, November, and December. Cause: The student?s enrollment status between Montgomery College?s student information system and in the National Student Clearinghouse matched upon the first notification of an error. The college certified the National Student Clearinghouse information on October 9, 2019 and subsequently on November 11 and November 20, 2019. However, the National Student Clearinghouse did not transmit the updates to NSLDS. Once the student reappeared on the December 2019 error report, a recertification was processed by the College directly in the NSLDS on January 15, 2020 which finally resolved the error. Effect: Student enrollment statuses may not be correctly or timely reported to the NSLDS. Repeat Finding: No. Recommendation: We recommend that the College continue to refine and implement processes to ensure determination of all students who withdraw, graduate, or have a change in status are accurately and timely reported to NSLDS. Management response and Corrective Action Plan: Refer to the College?s response on their letterhead as attached.

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