College of Idaho

Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit finding and is committed to strengthening internal controls over enrollment status reporting to ensure continued compliance with federal requirements. During management’s review of the audit results, the Registrar’s Office was unable to reproduce the specific enrollment status reporting errors identified during audit testing and could not definitively determine how the errors occurred. Notwithstanding this, the College recognizes that weaknesses in monitoring and documentation contributed to the inability to detect and prevent the reporting discrepancies in a timely manner. Accordingly, management has developed the following corrective actions. The College will enhance coordination among Registrar’s Office, Financial Aid, and Information Technology to ensure enrollment status changes including graduation, withdrawal, and changes in enrollment status are identified promptly and reported accurately to the National Student Loan Data System (NSLDS) within the required 60-day timeframe in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. For over 20 years, the College of Idaho has been a member of the National Student Clearinghouse (NSCH). One of the many advantages of membership to the NSCH is that the NSCH serves as a conduit to NSLDS and sends reports to the NSLDS for the college. Ellucian Colleague has written a series of reports that result in a .txt file that is uploaded to NSCH who in turn uploads to NSLDS. The College of Idaho submits regular transmissions to NSCH so that the 60-day timeframe is met. Corrective Action Plan: • Process Review and Clarification of Roles The Registrar’s Office will review and formalize procedures related to enrollment status determination and reporting. Roles and responsibilities for identifying enrollment changes, preparing NSLDS files, and submitting updates will be clearly documented to ensure accountability and continuity. • Student Information System Reporting Improvements The College will refine and validate student information system (SIS) reports used for enrollment reporting to ensure accurate capture of enrollment status changes and effective dates. Reports will be reviewed regularly to confirm continued reliability. • Internal Review and Oversight Controls Prior to submission to NSCH, enrollment status reports will be reviewed by the Registrar supervisory personnel to confirm accuracy and completeness. Evidence of review will be retained in accordance with institutional record retention practices. • Established Reporting Timeline A recurring reporting calendar will be implemented to ensure enrollment status updates are submitted within required federal timeframes. Backup personnel will be identified to support continuity during staff absences. • Training and Ongoing Communication Staff involved in enrollment reporting will receive periodic training on federal enrollment reporting requirements and institutional procedures. Regular communication between Enrollment Services and Financial Aid will support timely identification and resolution of discrepancies. Responsible Official(s): Mark Heidrich (Registrar/Associate Vice President for Institutional Effectiveness), in coordination with Stephanie House (Director of Financial Aid) and Imad Sweidan (Chief Information Officer), as appropriate. Anticipated Completion Date: June 30, 2026 Current Status: Corrective action is in progress. Management expects these actions to be fully implemented prior to the next audit period and believes the strengthened controls will prevent recurrence of this finding.

Finding 2021-001 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing Numbers: 84.268, 84.063, 84.007, 84.033 Finding Summary: During Eide Bailly?s review of the Return of Title IV Funds calculations, there was one instance out of eight students tested in which the Title IV funds to be returned was calculated incorrectly, resulting in the incorrect amount of funds being returned to the Department of Education. Responsible Individuals: Terri Scott, Director of Student Financial Aid Corrective Action Plan: The finding noted above resulted in a miscalculation of $113, but the College takes all exceptions in financial aid seriously. In response to the finding, the Director of Financial Aid developed a ?Pell Variance Report? to facilitate monthly reviews of the Federal grant awards to ensure amounts are accurate before the College begins the Return of Title IV Funds (R2T4) process. In addition to utilizing the Pell Variance Report, the Director of Financial Aid is reviewing R2T4 calculations based on the Department of Education calculator, and the Assistant Director of Financial Aid is reviewing R2T4 calculations based on the College?s internal computer system (Ellucian). The two independent calculations are then reconciled before submission. Lastly, the Director of Financial Aid is generating monthly reports in National Student Loan Data System (NSLDS), National Student Clearinghouse (NSC) and Common Origination and Disbursement system (COD) on a monthly basis and reviews the submitted information to confirm it was properly received by the Department of Education. All exceptions are immediately addressed. Anticipated Completion Date: Ongoing

Finding 2021-002 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing Numbers: 84.268, 84.063, 84.007, 84.033 Finding Summary: During Eide Bailly?s review Pell amounts awarded and disbursed, they noted 2 instances out of 68 students tested where the students did not receive the appropriate award. The initial calculation of the Pell award was made using the 2019-2020 Pell Schedule (as published by the U.S. Department of Education), and was not updated for the 2020-2021 Pell Schedule, after the 2020-2021 schedule was released. Responsible Individuals: Terri Scott, Director of Student Financial Aid Corrective Action Plan: As noted in the first finding, the two exceptions resulted in an incorrect award totaling $113. In order to better understand the underlying issue creating the finding the Financial Aid Department performed the following additional analysis of all Pell awards for 2020-21: ? Recalculated all Pell awards granted. ? Created a ?Pell Variance Report? in the College?s report writing system (Informer). This report lists the amount of the Pell award the student was eligible for as well as the amount of Pell the student was ultimately awarded. This allowed the Financial Aid Department to accurately compare the two calculations and identify any inconsistencies. ? The Financial Aid Department reviewed all Pell amounts for eligible students particularly those from the variance report, which included reviewing the Cost of Attendance (COA), Expected Family Contribution (EFC) and enrollment status. Through this process, the Financial Aid Department was able to satisfactorily determine that the finding was isolated to the two students identified during Eide Bailly?s testing. All others Pell awarded students were paid correctly. By identifying the underlying issue, the Director of Financial Aid developed additional procedures to ensure the Financial Aid Department accurately processes Pell disbursements. On a monthly basis and depending on the circumstances, additional procedures may consist of a combination of the following: ? The Director of Financial Aid reviewing the newly created Pell Variance Report monthly and research and correct any discrepancies. ? Using another Financial Aid report, the Department will review important student data such as EFC, COA, enrollment status, etc., and use this information in conjunction with the student?s Title IV eligibility to ensure disbursing financial aid accurately and to determine any needed changes to student?s Title IV aid. ? Generate a complete list of students who have been awarded Pell for the year to confirm the student was awarded using the proper Pell chart. ? Manually spot check one or two students every couple months and verify that student information is correct. Anticipated Completion: Ongoing

Finding #1 (Significant Finding) Initial Fiscal Year Finding Occurred: Fiscal year ending June 2019 Finding Summary: Issue: Out of 577 students included in the testing population, there were 7 instances where a student?s enrollment status per the college did not agree to the enrollment status found in the National Student Loan Data System for Students (NSLDS). Background: Enrollment reporting for The College of Idaho (College) was submitted to the National Student Clearinghouse (NSC) with trust that the enrollment information for each student was correctly and timely submitted to NSLDS. During the audit, exceptions were noted in the processing of student information, and calls were made to NSC to identify the gap in reporting. Student data was discovered by reviewing the College?s submitted report compared to NSC students listed as enrolled. NSC did not process the student information correctly, nor did they provide a response as to the missing enrollment reporting to NSLDS. Responsible Individuals: Jennifer Worden, Financial Aid Director Corrective Action Plan: The preparation and submission of the Enrollment Report to National Student Loan Data System (NSLDS) is a joint effort between the Registrar?s Office and the Financial Aid Department. The Departments engage and rely on National Student Clearinghouse (NSC) to properly process and submit their Enrollment Report information to NSLDS. Upon close examination, the College found the transmittal file representing student enrollment and withdrawal information sent by NSC to be incomplete. To validate the accuracy of the Enrollment Reporting transmittal file in the future and to address the finding noted, the Financial Aid Department will run tests and draw monthly samples from the NSC transmittal file sent to NSLDS and compare the reported information against the College?s original submission. Working directly with NSC, exceptions will be reviewed and corrected by the Financial Aid Director. Anticipated Completion Date: Ongoing Summary Schedule of Prior Audit Findings Finding #1 (Significant Finding) Initial Fiscal Year Finding Occurred: Fiscal year ending June 2018 Finding Summary: Issue: Student withdrawal was incorrectly calculated resulting in the College not remitting funds back to the Federal Government. In this instance, the student?s R2T4 was incorrectly calculated due to a system percentage difference, resulting in incorrect amount of funds sent to the Federal Government. Financial Aid procedures were properly followed, but the percentage calculated was incorrect and entered into changeable field in Colleague. Responsible Individuals: Jennifer Worden, Financial Aid Director Corrective Action Plan: Though the Director of Financial Aid agrees with the finding and the returned funding amount was incorrect, the circumstances surrounding the error are still under review. The College, working with its Information Technology Department and with its system service provider (Ellucian), is analyzing the activity related to the processing of the return of Title IV funding in order to evaluate whether the error was system generated, or an error was caused by processing the student withdrawal incorrectly by the Financial Aid Department. Irrespective of the outcome, the Director of Financial Aid has already evaluated processing controls to ensure that each return of Title IV (R2T4) calculation is processed correctly. The Department has initiated a procedure that uses two independent computations to verify the return of funding. The College continues to process withdrawals through the Ellucian system, and then computes the withdrawal using the Department of Education system. All differences are reconciled to ensure the proper amount is reported in the final submission to the Department of Education. In addition, during each academically enrolled month, the Financial Aid Director runs a Department of Education status report of all Return of Title IV students to ensure the information has been properly received by the Department of Education. Anticipated Completion Date: Completed, and no exceptions noted during the current year?s audit.

GSA_MIGRATION

GSA_MIGRATION

2016-001

GSA_MIGRATION

GSA_MIGRATION