Audit 15908

Criteria: Institutions must report all loan disbursements and submit required records to the Common Origination and Disbursement System (COD) within 15 days of disbursement (OMB No. 1845-0021). Direct Loan School Account Statement (SAS) reconciliations are a mandatory monthly process, as required under 34 CFR 685.300(b)(5). A school should reconcile all cash (drawdowns and refunds of cash) and disbursement records (actual disbursements and adjustments) with information in the Common Origination and Disbursement (COD) System on an ongoing basis. Condition/Context: For the period under audit, supporting evidence that SAS data files were reconciled to the University’s financial records could not be provided. Cause: The Universitys SAS data files and their reconciliation to internal financial records were not properly documented and retained. Effect: Lack of reconciliation procedures could result in improper data and within the COD system and noncompliance in cash management of the direct loan program and/or noncompliance with disbursement reporting requirements. Questioned Costs: Not applicable Recommendation: The University should put into place policies and procedures to ensure compliance with federal grant reporting requirements, including documenting and retaining monthly SAS reconciliations. Management’s Response: Management understands the finding and will seek to add documentation control procedures to ensure evidence of reconciliations are maintained.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: There was a lack of controls over the process of reporting student enrollment data to NSLDS. The following exceptions were noted in our testing of enrollment status change reporting for 25 students:  Eight students' status change effective dates reported to National Student Loan Database System (NSLDS) did not agree to the support provided from the University's system at either the campus level, program-level or both.  Three of the students mentioned above, also had incorrect status changes reported the NSLDS at the program-level. The sample was not a statistically valid sample. Cause: The University's controls surrounding NSLDS enrollment reporting did not detect or appropriately handle errors and omissions in the reporting. Effect: Incorrect information was reported to NSLDS. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students. Controls should be implemented that include review of data submitted to NSLDS and reconciliation of the information NSLDS retains to the underlying enrollment data should be performed. Management's Response: The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.

Criteria: Institutions must report all loan disbursements and submit required records to the Common Origination and Disbursement System (COD) within 15 days of disbursement (OMB No. 1845-0021). Direct Loan School Account Statement (SAS) reconciliations are a mandatory monthly process, as required under 34 CFR 685.300(b)(5). A school should reconcile all cash (drawdowns and refunds of cash) and disbursement records (actual disbursements and adjustments) with information in the Common Origination and Disbursement (COD) System on an ongoing basis. Condition/Context: For the period under audit, supporting evidence that SAS data files were reconciled to the University’s financial records could not be provided. Cause: The Universitys SAS data files and their reconciliation to internal financial records were not properly documented and retained. Effect: Lack of reconciliation procedures could result in improper data and within the COD system and noncompliance in cash management of the direct loan program and/or noncompliance with disbursement reporting requirements. Questioned Costs: Not applicable Recommendation: The University should put into place policies and procedures to ensure compliance with federal grant reporting requirements, including documenting and retaining monthly SAS reconciliations. Management’s Response: Management understands the finding and will seek to add documentation control procedures to ensure evidence of reconciliations are maintained.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: There was a lack of controls over the process of reporting student enrollment data to NSLDS. The following exceptions were noted in our testing of enrollment status change reporting for 25 students:  Eight students' status change effective dates reported to National Student Loan Database System (NSLDS) did not agree to the support provided from the University's system at either the campus level, program-level or both.  Three of the students mentioned above, also had incorrect status changes reported the NSLDS at the program-level. The sample was not a statistically valid sample. Cause: The University's controls surrounding NSLDS enrollment reporting did not detect or appropriately handle errors and omissions in the reporting. Effect: Incorrect information was reported to NSLDS. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students. Controls should be implemented that include review of data submitted to NSLDS and reconciliation of the information NSLDS retains to the underlying enrollment data should be performed. Management's Response: The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.