Lane Community College

2025-001 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P240357, P268K250357 Award Year: 2024-25 Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context: We selected a sample of 40 students out of a population of 994 who had received Federal aid and had withdrawn or graduated from the College during the 2024-2025 fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the College’s records. Effect: We noted one student was not reported to NSLDS within the 60-day requirement. In addition, we identified 20 students who either graduated or withdrew but were not reported as such to NSLDS. Lastly, we identified 2 students whose campus level detail did not agree with the program level detail reported to NSLDS. We believe this to be a representative sample of the population; however, it was not intended to be statistically valid. Questioned costs: None. Cause: This occurred because of lack of controls and oversight of the process. This resulted in late and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding: Yes, 2024-002 Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Views of responsible officials and planned corrective actions: Management agrees with the finding, see attached corrective action plan.

2025-001 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P240357, P268K250357 Award Year: 2024-25 Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context: The auditors selected a sample of 40 students out of a population of 994 who had received Federal aid and had withdrawn or graduated from the College during the 2024-2025 fiscal year. The auditors compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the College’s records. The auditors noted one student was not reported to NSLDS within the 60-day requirement. In addition, the auditors identified 20 students who either graduated or withdrew but were not reported as such to NSLDS. Lastly, the auditors identified 2 students whose campus level detail did not agree with the program level detail reported to NSLDS. Corrective Action: The FY2025 audit finding reflects that the corrective actions identified in the 2024 Corrective Action Plan were still in progress and being operationalized as of June 30, 2025. Lane Community College began implementing corrective measures following submission of the 2024 CAP in May 2025, with process updates and controls continuing to be implemented through Summer and Fall 2025. As a result, not all procedural changes had been fully implemented or consistently applied during the audit review period. Since that time, the institution has continued to refine its enrollment reporting processes to ensure compliance with National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) reporting requirements. Building on the initial controls established through the 2024 CAP, Lane has implemented additional process improvements and is continuing to formalize and standardize reporting procedures to address gaps identified during the 2025 audit. Key corrective actions for 2025 include: • Formalizing written procedures that clearly document institutional responsibilities and processes related to enrollment reporting, including definitions and use of Last Date of Attendance (LDA), Date of Determination (DOD), and R2T4 determinations. • Providing staff training on updated NSC and NSLDS reporting requirements to ensure consistent identification and reporting of enrollment status changes. • Reviewing and refining reporting schedules to align reporting frequency with federal requirements while ensuring timely reporting of enrollment changes within the required 30-day reporting window. • Implementing monitoring tools • Conducting degree verification reporting reviews • Reviewing data sources used for reporting to confirm enrollment and completion data are transmitted from the appropriate systems and fields within Banner. • Continuing internal monitoring of NSC error reports These actions are intended to address procedural gaps identified during the continued review of enrollment reporting processes, particularly those related to consistent identification and reporting of enrollment status changes tied to Last Date of Attendance and Date of Determination. The Registrar’s Office, Financial Aid Office, and Enrollment Systems staff will continue coordinating oversight of NSC reporting activities. Lane Community College is continuing to formalize documentation of updated procedures and expects ongoing refinement of these processes through the current academic year to support consistent application and compliance with NSC, NSLDS, and Federal Title IV reporting requirements. Name of Contact Person Responsible for Corrective Action: Dawn Whiting Anticipated Completion Date for the Corrective Action: April 15, 2026

2024-002

2024-002 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P230357, P268K230357 Award Year: 2023-24 Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Condition/context: We selected a sample of 34 students out of a population of 1,454 who had received Federal aid and had withdrawn or graduated from the College during the 2023-2024 fiscal year. We compared the withdrawal or graduation date per the College’s records to NSLDS. We noted eight students were not reported to NSLDS within the 60-day requirement. In addition, we identified ten students who graduated but were not reported as graduated to NSLDS. Our sample was not, and was not intended to be, statistically valid. Questioned costs: None. Cause/Effect: This occurred because of lack of controls and oversight of the process. This resulted in late and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding: No Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Views of responsible officials and planned corrective actions: Management agrees with the finding and are working to allocate more staff to support the process and reviewing reporting requirements to ensure they are meeting the reporting requirements.

2024-002 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P230357, P268K230357 Award Year: 2023-24 Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Condition/context: The auditors selected a sample of 34 students out of a population of 1,454 who had received Federal aid and had withdrawn or graduated from the College during the 2023-2024 fiscal year. The auditors compared the withdrawal or graduation date per the College’s records to NSLDS. The auditors noted eight students were not reported to NSLDS within the 60-day requirement. In addition, the auditors identified ten students who graduated but were not reported as graduated to NSLDS. Corrective Action: LCC reports enrollment to the National Student Clearinghouse: in the second, sixth and the tenth week of each standard term. There is an error report that the Clearinghouse returns with discrepancies in enrollment status which we respond to and correct within five business days. Once all errors are resolved and the report is accepted the NSC will post the data and report to NSLDS. Lane is an open access institution and therefore does not have a formal withdrawal policy. Two weeks after the end of each term, Lane sends the enrollment report and the “degree verify” extract to NSC. We are in the process of reviewing our NSC reporting strategies and including additional staff who will be supporting the process. We are reviewing NSC reporting times to ensure that we are reporting often enough to meet the required 60 day timeline for NSLDS. We are considering moving the enrollment and degree verify extract to a 30 day reporting period to meet the 60 day timeline. Phase 1: Issue an off cycle report to the NSC by June 6th, which is our next anticipated enrollment reporting cycle (week ten). We will send both the enrollment report and the “degree verify” extract to catch any updates to graduation information that may have changed since our last end of term report. Phase 2: Review updates to NSC processes that were issued through Banner and Ellucian and revise the “degree verify” process to capture regular graduation or withdrawal updates outside our standard reporting window. Unless it is discovered that the 30 day cycle does not meet the requirements of the reporting cycle, we will update our processes to - at a minimum - report every 30 days or in alignment with the weeks two, six and ten current enrollment report to the NSC. Additionally, the students noted in the finding will be reviewed to address any potential anomalies with reporting and to identify the cause of why these were not updated. This will be another consideration during the assessment for any updates to our reporting cycles. Following spring term, we will report graduated and withdrawn students, as is our current practice and after student degree awarding is complete. Name of Contact Person Responsible for Corrective Action: Dawn Whiting Anticipated Completion Date for the Corrective Action: A review process of 90 days should result in refined practices and an implementation of those practices to meet required reporting. All reporting changes will be finalized and followed by Aug 21, 2025.