Audit 292920

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: For 2 of the 25 students tested, the effective date between the College's support and campus level enrollment detail did not match and was not corrected within the required time frame. For 1 of the 25 students, their graduated status was never reported to the NSLDS. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide. Cause: The College failed to follow its procedures for reporting student status changes accurately and timely. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. 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. Questioned Costs: Not applicable Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and enrollment statuses are reported to the NSLDS within the required time frames after the information has been submitted through the servicer (NSC). This could include a review of withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. Management's Response: We identified two issues that led to inaccurate reporting of enrollment statuses to NSLDS. One was human error; the other was a result of an override we had in the report to pull enrollment data. Our Institutional Research Office had the overrides in the enrollment report removed and developed a system where they will upload enrollment reports monthly to the Clearinghouse which will then update enrollment in NSLDS. We are also researching the possibility of reviewing withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. At the time of the audit, a graduation date that past had not been reported to NSLDS. We did not have the final transcript from the study abroad institution to confirm all graduation requirements had been met. The graduation date has since been reported but it was not within the required timeframe. In the future we plan to do more aggressive outreach to the study abroad institution to receive final transcripts sooner.

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: For 2 of the 25 students tested, the effective date between the College's support and campus level enrollment detail did not match and was not corrected within the required time frame. For 1 of the 25 students, their graduated status was never reported to the NSLDS. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide. Cause: The College failed to follow its procedures for reporting student status changes accurately and timely. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. 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. Questioned Costs: Not applicable Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and enrollment statuses are reported to the NSLDS within the required time frames after the information has been submitted through the servicer (NSC). This could include a review of withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. Management's Response: We identified two issues that led to inaccurate reporting of enrollment statuses to NSLDS. One was human error; the other was a result of an override we had in the report to pull enrollment data. Our Institutional Research Office had the overrides in the enrollment report removed and developed a system where they will upload enrollment reports monthly to the Clearinghouse which will then update enrollment in NSLDS. We are also researching the possibility of reviewing withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. At the time of the audit, a graduation date that past had not been reported to NSLDS. We did not have the final transcript from the study abroad institution to confirm all graduation requirements had been met. The graduation date has since been reported but it was not within the required timeframe. In the future we plan to do more aggressive outreach to the study abroad institution to receive final transcripts sooner.