Audit 291202

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: The change in student status for 7 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) timely when the students graduated at the end of the spring term. The change in status for 2 of 25 students tested was not reported to NSLDS at the campus level. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Cause: The Registrar's data collection was not reviewed after submission to National Student Clearinghouse (NSC) by another responsible individual to ascertain the accuracy of graduated students being reported. The College received a response from NSC of no errors, therefore the graduated students in question were not reported in a timely manner. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an Institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues with the third-party servicer in a timely manner or implement an alternative reporting method to facilitate compliance with Title IV regulations. Management’s Response: Management has reviewed policies and procedures for accurate reporting of enrollment status and changes to be in compliance with federal regulations. The College will designate a secondary responsible individual to conduct a review of the preparation of the digital file and review the digital file of student enrollment changes before it is submitted to the National Student Loan Clearinghouse. The Office of Financial Planning will conduct monthly review as a secondary review of enrollment reporting in the National Student Loan Data System (NSLDS).

Criteria: The College is required to submit ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. By October 1, 2022, the institution should submit its FISAP that includes the Fiscal Operations Report for the award year 2021–2022 and the Application to Participate for the 2022–2023 award year (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Condition/Context: For Part III, Fiscal Operations Report, line 5.3 reflected an amount lent of $481,714 and the underlying support reflects this amount as $200,550. Line 5.4 reflected an amount lent of $21,905,651, and the support reflects this amount as $481,714. The sample was not a statistically valid sample. Questioned Costs: Not applicable Cause: The College’s internal controls related to the preparation and review of the annual FISAP report was not effective to catch the errors in the reporting on a timely basis. Effect: The College reported incorrect information on the FISAP report to the Department of Education. Recommendation: It is recommended that the College review policies and procedures in place to ensure accurate reporting to comply with Title IV regulations. Management’s Response: Management has reviewed procedures and policy for accurate FISAP reporting to be in compliance with federal regulations. The College will conduct review by the Loras College alternative responsible official prior to final submission of the FISAP to be sure data inputs are accurate.

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: The change in student status for 7 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) timely when the students graduated at the end of the spring term. The change in status for 2 of 25 students tested was not reported to NSLDS at the campus level. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Cause: The Registrar's data collection was not reviewed after submission to National Student Clearinghouse (NSC) by another responsible individual to ascertain the accuracy of graduated students being reported. The College received a response from NSC of no errors, therefore the graduated students in question were not reported in a timely manner. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an Institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues with the third-party servicer in a timely manner or implement an alternative reporting method to facilitate compliance with Title IV regulations. Management’s Response: Management has reviewed policies and procedures for accurate reporting of enrollment status and changes to be in compliance with federal regulations. The College will designate a secondary responsible individual to conduct a review of the preparation of the digital file and review the digital file of student enrollment changes before it is submitted to the National Student Loan Clearinghouse. The Office of Financial Planning will conduct monthly review as a secondary review of enrollment reporting in the National Student Loan Data System (NSLDS).

Criteria: The College is required to submit ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. By October 1, 2022, the institution should submit its FISAP that includes the Fiscal Operations Report for the award year 2021–2022 and the Application to Participate for the 2022–2023 award year (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Condition/Context: For Part III, Fiscal Operations Report, line 5.3 reflected an amount lent of $481,714 and the underlying support reflects this amount as $200,550. Line 5.4 reflected an amount lent of $21,905,651, and the support reflects this amount as $481,714. The sample was not a statistically valid sample. Questioned Costs: Not applicable Cause: The College’s internal controls related to the preparation and review of the annual FISAP report was not effective to catch the errors in the reporting on a timely basis. Effect: The College reported incorrect information on the FISAP report to the Department of Education. Recommendation: It is recommended that the College review policies and procedures in place to ensure accurate reporting to comply with Title IV regulations. Management’s Response: Management has reviewed procedures and policy for accurate FISAP reporting to be in compliance with federal regulations. The College will conduct review by the Loras College alternative responsible official prior to final submission of the FISAP to be sure data inputs are accurate.