Audit 298073

FINDING 2023-001 Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Enrollment Reporting Federal Agency: Department of Education Federal Programs: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listings Numbers: 84.063, 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Audit Findings: Material Weakness, Other Matters Condition and Context As a recipient of Title IV funding from the Federal Pell Grant Program (Pell) and Federal Direct Student Loans program (direct loan), the University was responsible for reporting accurate enrollment information for students receiving those awards to the National Student Loan Data System (NSLDS). Enrollment reporting requires the University to review, update, and certify student enrollment statuses, program information, and effective dates for each student receiving a Pell and/or direct loan award with a change in its enrollment information. Although the University had policies and procedures in place over Enrollment Reporting, a specific process to ensure system defects did not impact reporting requirements was not implemented. As such, errors in reporting campus level and program level data went undetected. A sample of 40 students was selected to determine if the University was notifying the Department of Education of changes in student enrollment information in a timely and accurate manner. Of the 40 students tested, 11 students had incorrect enrollment effective dates reported to the NSLDS for both campus-level and program level data. Follow-up procedures determined that the issue was isolated to students in the Spring 2023 term who had a change in enrollment status from the census date to the end of the term. The issue was a result of a system defect that pulled the wrong dates into the report the University used to submit the data to the NSLDS. The issue affected 160 students out of a total of 6,952 students. The lack of effective internal controls was a systemic issue throughout the audit period, while the noncompliance was isolated to the Spring 2023 term. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 14 UNIVERSITY OF SOUTHERN INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 685.309(b) states in part: "Enrollment reporting process. (1) Upon receipt of an enrollment report from the Secretary, a school must update all information 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. . . ." The 2022-2023 Federal Student Aid Handbook, Volume 2, Chapter 3 states in part: "Sharing Information With NSLDS, Federal Loan Servicers, And Guarantors Reporting student enrollment data to NSLDS Student enrollment information is important, and all schools participating or approved to participate in the FSA programs must have online enrollment access and have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. Enrollment information is used to determine if the student is still considered in school, must be moved into repayment, or is eligible for an inschool deferment. Program-level enrollment data is also used to determine a student's eligibility for Direct Subsidized Loans. For students moving into repayment, the out-of-school status effective date determines when the grace period begins and how soon a student must begin repaying loan funds. You're required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date. . . ." Cause A proper system of internal controls over enrollment reporting was not effective to ensure that accurate enrollment data was submitted to the NSLDS. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the University's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, enrollment information was not properly submitted to the NSLDS. Questioned Costs There were no questioned costs identified. Recommendation We recommended the University's management establish a system of internal controls that includes a review of Banner job processes to verify source data is correctly populated so as to ensure that all data elements required to be submitted to the NSLDS are accurate. INDIANA STATE BOARD OF ACCOUNTS 15 UNIVERSITY OF SOUTHERN INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2023-001 Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Enrollment Reporting Federal Agency: Department of Education Federal Programs: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listings Numbers: 84.063, 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Audit Findings: Material Weakness, Other Matters Condition and Context As a recipient of Title IV funding from the Federal Pell Grant Program (Pell) and Federal Direct Student Loans program (direct loan), the University was responsible for reporting accurate enrollment information for students receiving those awards to the National Student Loan Data System (NSLDS). Enrollment reporting requires the University to review, update, and certify student enrollment statuses, program information, and effective dates for each student receiving a Pell and/or direct loan award with a change in its enrollment information. Although the University had policies and procedures in place over Enrollment Reporting, a specific process to ensure system defects did not impact reporting requirements was not implemented. As such, errors in reporting campus level and program level data went undetected. A sample of 40 students was selected to determine if the University was notifying the Department of Education of changes in student enrollment information in a timely and accurate manner. Of the 40 students tested, 11 students had incorrect enrollment effective dates reported to the NSLDS for both campus-level and program level data. Follow-up procedures determined that the issue was isolated to students in the Spring 2023 term who had a change in enrollment status from the census date to the end of the term. The issue was a result of a system defect that pulled the wrong dates into the report the University used to submit the data to the NSLDS. The issue affected 160 students out of a total of 6,952 students. The lack of effective internal controls was a systemic issue throughout the audit period, while the noncompliance was isolated to the Spring 2023 term. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 14 UNIVERSITY OF SOUTHERN INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 685.309(b) states in part: "Enrollment reporting process. (1) Upon receipt of an enrollment report from the Secretary, a school must update all information 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. . . ." The 2022-2023 Federal Student Aid Handbook, Volume 2, Chapter 3 states in part: "Sharing Information With NSLDS, Federal Loan Servicers, And Guarantors Reporting student enrollment data to NSLDS Student enrollment information is important, and all schools participating or approved to participate in the FSA programs must have online enrollment access and have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. Enrollment information is used to determine if the student is still considered in school, must be moved into repayment, or is eligible for an inschool deferment. Program-level enrollment data is also used to determine a student's eligibility for Direct Subsidized Loans. For students moving into repayment, the out-of-school status effective date determines when the grace period begins and how soon a student must begin repaying loan funds. You're required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date. . . ." Cause A proper system of internal controls over enrollment reporting was not effective to ensure that accurate enrollment data was submitted to the NSLDS. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the University's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, enrollment information was not properly submitted to the NSLDS. Questioned Costs There were no questioned costs identified. Recommendation We recommended the University's management establish a system of internal controls that includes a review of Banner job processes to verify source data is correctly populated so as to ensure that all data elements required to be submitted to the NSLDS are accurate. INDIANA STATE BOARD OF ACCOUNTS 15 UNIVERSITY OF SOUTHERN INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2023-001 Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Enrollment Reporting Federal Agency: Department of Education Federal Programs: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listings Numbers: 84.063, 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Audit Findings: Material Weakness, Other Matters Condition and Context As a recipient of Title IV funding from the Federal Pell Grant Program (Pell) and Federal Direct Student Loans program (direct loan), the University was responsible for reporting accurate enrollment information for students receiving those awards to the National Student Loan Data System (NSLDS). Enrollment reporting requires the University to review, update, and certify student enrollment statuses, program information, and effective dates for each student receiving a Pell and/or direct loan award with a change in its enrollment information. Although the University had policies and procedures in place over Enrollment Reporting, a specific process to ensure system defects did not impact reporting requirements was not implemented. As such, errors in reporting campus level and program level data went undetected. A sample of 40 students was selected to determine if the University was notifying the Department of Education of changes in student enrollment information in a timely and accurate manner. Of the 40 students tested, 11 students had incorrect enrollment effective dates reported to the NSLDS for both campus-level and program level data. Follow-up procedures determined that the issue was isolated to students in the Spring 2023 term who had a change in enrollment status from the census date to the end of the term. The issue was a result of a system defect that pulled the wrong dates into the report the University used to submit the data to the NSLDS. The issue affected 160 students out of a total of 6,952 students. The lack of effective internal controls was a systemic issue throughout the audit period, while the noncompliance was isolated to the Spring 2023 term. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 14 UNIVERSITY OF SOUTHERN INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 685.309(b) states in part: "Enrollment reporting process. (1) Upon receipt of an enrollment report from the Secretary, a school must update all information 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. . . ." The 2022-2023 Federal Student Aid Handbook, Volume 2, Chapter 3 states in part: "Sharing Information With NSLDS, Federal Loan Servicers, And Guarantors Reporting student enrollment data to NSLDS Student enrollment information is important, and all schools participating or approved to participate in the FSA programs must have online enrollment access and have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. Enrollment information is used to determine if the student is still considered in school, must be moved into repayment, or is eligible for an inschool deferment. Program-level enrollment data is also used to determine a student's eligibility for Direct Subsidized Loans. For students moving into repayment, the out-of-school status effective date determines when the grace period begins and how soon a student must begin repaying loan funds. You're required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date. . . ." Cause A proper system of internal controls over enrollment reporting was not effective to ensure that accurate enrollment data was submitted to the NSLDS. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the University's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, enrollment information was not properly submitted to the NSLDS. Questioned Costs There were no questioned costs identified. Recommendation We recommended the University's management establish a system of internal controls that includes a review of Banner job processes to verify source data is correctly populated so as to ensure that all data elements required to be submitted to the NSLDS are accurate. INDIANA STATE BOARD OF ACCOUNTS 15 UNIVERSITY OF SOUTHERN INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2023-001 Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Enrollment Reporting Federal Agency: Department of Education Federal Programs: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listings Numbers: 84.063, 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Audit Findings: Material Weakness, Other Matters Condition and Context As a recipient of Title IV funding from the Federal Pell Grant Program (Pell) and Federal Direct Student Loans program (direct loan), the University was responsible for reporting accurate enrollment information for students receiving those awards to the National Student Loan Data System (NSLDS). Enrollment reporting requires the University to review, update, and certify student enrollment statuses, program information, and effective dates for each student receiving a Pell and/or direct loan award with a change in its enrollment information. Although the University had policies and procedures in place over Enrollment Reporting, a specific process to ensure system defects did not impact reporting requirements was not implemented. As such, errors in reporting campus level and program level data went undetected. A sample of 40 students was selected to determine if the University was notifying the Department of Education of changes in student enrollment information in a timely and accurate manner. Of the 40 students tested, 11 students had incorrect enrollment effective dates reported to the NSLDS for both campus-level and program level data. Follow-up procedures determined that the issue was isolated to students in the Spring 2023 term who had a change in enrollment status from the census date to the end of the term. The issue was a result of a system defect that pulled the wrong dates into the report the University used to submit the data to the NSLDS. The issue affected 160 students out of a total of 6,952 students. The lack of effective internal controls was a systemic issue throughout the audit period, while the noncompliance was isolated to the Spring 2023 term. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 14 UNIVERSITY OF SOUTHERN INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 685.309(b) states in part: "Enrollment reporting process. (1) Upon receipt of an enrollment report from the Secretary, a school must update all information 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. . . ." The 2022-2023 Federal Student Aid Handbook, Volume 2, Chapter 3 states in part: "Sharing Information With NSLDS, Federal Loan Servicers, And Guarantors Reporting student enrollment data to NSLDS Student enrollment information is important, and all schools participating or approved to participate in the FSA programs must have online enrollment access and have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. Enrollment information is used to determine if the student is still considered in school, must be moved into repayment, or is eligible for an inschool deferment. Program-level enrollment data is also used to determine a student's eligibility for Direct Subsidized Loans. For students moving into repayment, the out-of-school status effective date determines when the grace period begins and how soon a student must begin repaying loan funds. You're required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date. . . ." Cause A proper system of internal controls over enrollment reporting was not effective to ensure that accurate enrollment data was submitted to the NSLDS. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the University's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, enrollment information was not properly submitted to the NSLDS. Questioned Costs There were no questioned costs identified. Recommendation We recommended the University's management establish a system of internal controls that includes a review of Banner job processes to verify source data is correctly populated so as to ensure that all data elements required to be submitted to the NSLDS are accurate. INDIANA STATE BOARD OF ACCOUNTS 15 UNIVERSITY OF SOUTHERN INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.