Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) – Federal Pell Grant Program (Federal Assistance Listing #84.063)
and Federal Direct Student Loans (Federal Assistance Listing #84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date.
Condition – The conditions at the campus level and program level were as follows:
Campus Level: For certain students that had enrollment status changes, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames and/or the Institute did not report the correct type of enrollment status change.
Program Level: For certain students that had enrollment status changes, the Institute incorrectly reported enrollment status, the program begin date, and/or the program enrollment effective date.
Cause - Administrative oversight in internal controls over enrollment reporting requirements.
Effect or Potential Effect - The Institute was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context at the campus level and program level is as follows:
Campus Level:
• For 13 of 17 students selected for testing, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames.
• For 4 of 17 students selected for testing, the Institute did not report the correct type of enrollment status change.
Program Level:
• For 4 of 17 students selected for testing, the enrollment status was incorrectly reported.
• For 2 of 17 students selected for testing, the program begin date was incorrectly reported.
• For 3 of 17 students selected for testing, the program enrollment effective date was incorrectly reported.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-001.
Recommendation – We recommend that the Institute enhance its procedures and its internal controls over enrollment reporting requirements.
Views of Responsible Officials – The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took several months to resolve. There was a lack of continuity in reporting due to technological deficiencies that required a team of resources beyond the one office. Once technological deficiencies were addressed, reporting had not been performed since September 2023 and the first enrollment report submitted under the new registrar caused data issues as it was for a new semester (Spring 2024). The corrective action plan includes:
• Continued student information system (“SIS”) training with Ellucian-Banner software personnel to include permissions-based access to data and software upgrades.
o Access to data is permissions-based and our IT department monitors this to make sure registrar staff has the correct access.
• Sweet Briar has authorized additional training for Registrar staff who are not familiar with the Banner SIS to ensure proper coding of student records.
• Working with the National Student Clearinghouse (“NSC”) to resolve issues with data uploads and training on how to resolve errors.
• Consistent reporting per the NSC transmission schedule so data is reported correctly and timely.
• Consistent reporting of separated students (withdrawn and graduated) within 30 days of departure.
• The registrar has conducted several reviews of SIS databases and tables to ensure the data is consistent with the Crosswalk provided by the National Student Clearinghouse, especially in enrollment status based on hours taken in a semester.
• Creation of a manual with step-by-step directions on how to generate a report, submit the data to the NSC, and how to resolve errors on the NSC portal so the loss of a key person in the registrar’s office assures compliance with reporting and continuity.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) – Federal Pell Grant Program (Federal Assistance Listing #84.063)
and Federal Direct Student Loans (Federal Assistance Listing #84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date.
Condition – The conditions at the campus level and program level were as follows:
Campus Level: For certain students that had enrollment status changes, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames and/or the Institute did not report the correct type of enrollment status change.
Program Level: For certain students that had enrollment status changes, the Institute incorrectly reported enrollment status, the program begin date, and/or the program enrollment effective date.
Cause - Administrative oversight in internal controls over enrollment reporting requirements.
Effect or Potential Effect - The Institute was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context at the campus level and program level is as follows:
Campus Level:
• For 13 of 17 students selected for testing, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames.
• For 4 of 17 students selected for testing, the Institute did not report the correct type of enrollment status change.
Program Level:
• For 4 of 17 students selected for testing, the enrollment status was incorrectly reported.
• For 2 of 17 students selected for testing, the program begin date was incorrectly reported.
• For 3 of 17 students selected for testing, the program enrollment effective date was incorrectly reported.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-001.
Recommendation – We recommend that the Institute enhance its procedures and its internal controls over enrollment reporting requirements.
Views of Responsible Officials – The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took several months to resolve. There was a lack of continuity in reporting due to technological deficiencies that required a team of resources beyond the one office. Once technological deficiencies were addressed, reporting had not been performed since September 2023 and the first enrollment report submitted under the new registrar caused data issues as it was for a new semester (Spring 2024). The corrective action plan includes:
• Continued student information system (“SIS”) training with Ellucian-Banner software personnel to include permissions-based access to data and software upgrades.
o Access to data is permissions-based and our IT department monitors this to make sure registrar staff has the correct access.
• Sweet Briar has authorized additional training for Registrar staff who are not familiar with the Banner SIS to ensure proper coding of student records.
• Working with the National Student Clearinghouse (“NSC”) to resolve issues with data uploads and training on how to resolve errors.
• Consistent reporting per the NSC transmission schedule so data is reported correctly and timely.
• Consistent reporting of separated students (withdrawn and graduated) within 30 days of departure.
• The registrar has conducted several reviews of SIS databases and tables to ensure the data is consistent with the Crosswalk provided by the National Student Clearinghouse, especially in enrollment status based on hours taken in a semester.
• Creation of a manual with step-by-step directions on how to generate a report, submit the data to the NSC, and how to resolve errors on the NSC portal so the loss of a key person in the registrar’s office assures compliance with reporting and continuity.
Finding 2024-002 – N. Special Tests and Provisions – Disbursements to or on Behalf of Students
Information on Federal Program(s) – Federal Work-Study Program (Federal Assistance Listing #84.033)
Criteria or Specific Requirement – For students receiving Federal Work-Study (“FWS”) Program funds, federal regulations (34 CFR 675.16) require institutions to pay FWS compensation at least once a month. Before an institution makes an initial disbursement of FWS compensation to a student for an award period, the institution must notify the student of the amount of funds the student is authorized to earn, and how and when the FWS compensation will be paid. Regardless of who employs the student, the institution is responsible for ensuring that the student is paid for work performed.
Condition – For certain students selected for testing, the Institute did not pay the student FWS compensation based on the correct hours worked. Additionally, certain students’ timesheets were not properly reviewed/approved.
Cause – Administrative oversight in internal controls over FWS disbursements.
Effect or Potential Effect – The Institute was not in compliance with FWS disbursement requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 40 pay periods selected for FWS testing, the amount of compensation disbursed to the student did not agree to the hours worked per the approved timesheet.
• For 4 of 40 pay periods selected for FWS testing, the students’ timesheet was not properly reviewed/approved by a supervisor as required.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and its internal controls to ensure that students receiving FWS compensation are paid timely, and for the correct amounts. Additionally, we recommend that student timesheets be approved prior to the disbursement of funds.
Views of Responsible Officials – The Institute agrees with the finding. Moving forward, when Student Employment payment information is entered into our Human Resource information system, the Institute will continuously check timecards to ensure that the wages match the number of hours students work. Furthermore, the Institute will stay in communication with student supervisors to ensure they are approving timecards before payroll is processed.
Finding 2024-003 – N. Special Tests and Provisions – Verification
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.007, #84.033, #84.063, #84.268)
Criteria or Specific Requirement – An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition – The Institute did not accurately verify all required information for a student.
Cause – Administrative oversight in internal controls over required verification procedures.
Effect or Potential Effect – The Institute was not in compliance with the verification requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 6 students selected for the Institute did not perform appropriate verification procedures including the verification of certain tax return information.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and internal controls to ensure appropriate verification procedures are performed for all students who are selected for verification.
Views of Responsible Officials – The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56).
The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified.
The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid.
Finding 2024-003 – N. Special Tests and Provisions – Verification
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.007, #84.033, #84.063, #84.268)
Criteria or Specific Requirement – An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition – The Institute did not accurately verify all required information for a student.
Cause – Administrative oversight in internal controls over required verification procedures.
Effect or Potential Effect – The Institute was not in compliance with the verification requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 6 students selected for the Institute did not perform appropriate verification procedures including the verification of certain tax return information.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and internal controls to ensure appropriate verification procedures are performed for all students who are selected for verification.
Views of Responsible Officials – The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56).
The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified.
The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid.
Finding 2024-003 – N. Special Tests and Provisions – Verification
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.007, #84.033, #84.063, #84.268)
Criteria or Specific Requirement – An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition – The Institute did not accurately verify all required information for a student.
Cause – Administrative oversight in internal controls over required verification procedures.
Effect or Potential Effect – The Institute was not in compliance with the verification requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 6 students selected for the Institute did not perform appropriate verification procedures including the verification of certain tax return information.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and internal controls to ensure appropriate verification procedures are performed for all students who are selected for verification.
Views of Responsible Officials – The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56).
The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified.
The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid.
Finding 2024-003 – N. Special Tests and Provisions – Verification
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.007, #84.033, #84.063, #84.268)
Criteria or Specific Requirement – An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition – The Institute did not accurately verify all required information for a student.
Cause – Administrative oversight in internal controls over required verification procedures.
Effect or Potential Effect – The Institute was not in compliance with the verification requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 6 students selected for the Institute did not perform appropriate verification procedures including the verification of certain tax return information.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and internal controls to ensure appropriate verification procedures are performed for all students who are selected for verification.
Views of Responsible Officials – The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56).
The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified.
The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) – Federal Pell Grant Program (Federal Assistance Listing #84.063)
and Federal Direct Student Loans (Federal Assistance Listing #84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date.
Condition – The conditions at the campus level and program level were as follows:
Campus Level: For certain students that had enrollment status changes, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames and/or the Institute did not report the correct type of enrollment status change.
Program Level: For certain students that had enrollment status changes, the Institute incorrectly reported enrollment status, the program begin date, and/or the program enrollment effective date.
Cause - Administrative oversight in internal controls over enrollment reporting requirements.
Effect or Potential Effect - The Institute was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context at the campus level and program level is as follows:
Campus Level:
• For 13 of 17 students selected for testing, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames.
• For 4 of 17 students selected for testing, the Institute did not report the correct type of enrollment status change.
Program Level:
• For 4 of 17 students selected for testing, the enrollment status was incorrectly reported.
• For 2 of 17 students selected for testing, the program begin date was incorrectly reported.
• For 3 of 17 students selected for testing, the program enrollment effective date was incorrectly reported.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-001.
Recommendation – We recommend that the Institute enhance its procedures and its internal controls over enrollment reporting requirements.
Views of Responsible Officials – The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took several months to resolve. There was a lack of continuity in reporting due to technological deficiencies that required a team of resources beyond the one office. Once technological deficiencies were addressed, reporting had not been performed since September 2023 and the first enrollment report submitted under the new registrar caused data issues as it was for a new semester (Spring 2024). The corrective action plan includes:
• Continued student information system (“SIS”) training with Ellucian-Banner software personnel to include permissions-based access to data and software upgrades.
o Access to data is permissions-based and our IT department monitors this to make sure registrar staff has the correct access.
• Sweet Briar has authorized additional training for Registrar staff who are not familiar with the Banner SIS to ensure proper coding of student records.
• Working with the National Student Clearinghouse (“NSC”) to resolve issues with data uploads and training on how to resolve errors.
• Consistent reporting per the NSC transmission schedule so data is reported correctly and timely.
• Consistent reporting of separated students (withdrawn and graduated) within 30 days of departure.
• The registrar has conducted several reviews of SIS databases and tables to ensure the data is consistent with the Crosswalk provided by the National Student Clearinghouse, especially in enrollment status based on hours taken in a semester.
• Creation of a manual with step-by-step directions on how to generate a report, submit the data to the NSC, and how to resolve errors on the NSC portal so the loss of a key person in the registrar’s office assures compliance with reporting and continuity.
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) – Federal Pell Grant Program (Federal Assistance Listing #84.063)
and Federal Direct Student Loans (Federal Assistance Listing #84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date.
Condition – The conditions at the campus level and program level were as follows:
Campus Level: For certain students that had enrollment status changes, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames and/or the Institute did not report the correct type of enrollment status change.
Program Level: For certain students that had enrollment status changes, the Institute incorrectly reported enrollment status, the program begin date, and/or the program enrollment effective date.
Cause - Administrative oversight in internal controls over enrollment reporting requirements.
Effect or Potential Effect - The Institute was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context at the campus level and program level is as follows:
Campus Level:
• For 13 of 17 students selected for testing, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames.
• For 4 of 17 students selected for testing, the Institute did not report the correct type of enrollment status change.
Program Level:
• For 4 of 17 students selected for testing, the enrollment status was incorrectly reported.
• For 2 of 17 students selected for testing, the program begin date was incorrectly reported.
• For 3 of 17 students selected for testing, the program enrollment effective date was incorrectly reported.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-001.
Recommendation – We recommend that the Institute enhance its procedures and its internal controls over enrollment reporting requirements.
Views of Responsible Officials – The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took several months to resolve. There was a lack of continuity in reporting due to technological deficiencies that required a team of resources beyond the one office. Once technological deficiencies were addressed, reporting had not been performed since September 2023 and the first enrollment report submitted under the new registrar caused data issues as it was for a new semester (Spring 2024). The corrective action plan includes:
• Continued student information system (“SIS”) training with Ellucian-Banner software personnel to include permissions-based access to data and software upgrades.
o Access to data is permissions-based and our IT department monitors this to make sure registrar staff has the correct access.
• Sweet Briar has authorized additional training for Registrar staff who are not familiar with the Banner SIS to ensure proper coding of student records.
• Working with the National Student Clearinghouse (“NSC”) to resolve issues with data uploads and training on how to resolve errors.
• Consistent reporting per the NSC transmission schedule so data is reported correctly and timely.
• Consistent reporting of separated students (withdrawn and graduated) within 30 days of departure.
• The registrar has conducted several reviews of SIS databases and tables to ensure the data is consistent with the Crosswalk provided by the National Student Clearinghouse, especially in enrollment status based on hours taken in a semester.
• Creation of a manual with step-by-step directions on how to generate a report, submit the data to the NSC, and how to resolve errors on the NSC portal so the loss of a key person in the registrar’s office assures compliance with reporting and continuity.
Finding 2024-002 – N. Special Tests and Provisions – Disbursements to or on Behalf of Students
Information on Federal Program(s) – Federal Work-Study Program (Federal Assistance Listing #84.033)
Criteria or Specific Requirement – For students receiving Federal Work-Study (“FWS”) Program funds, federal regulations (34 CFR 675.16) require institutions to pay FWS compensation at least once a month. Before an institution makes an initial disbursement of FWS compensation to a student for an award period, the institution must notify the student of the amount of funds the student is authorized to earn, and how and when the FWS compensation will be paid. Regardless of who employs the student, the institution is responsible for ensuring that the student is paid for work performed.
Condition – For certain students selected for testing, the Institute did not pay the student FWS compensation based on the correct hours worked. Additionally, certain students’ timesheets were not properly reviewed/approved.
Cause – Administrative oversight in internal controls over FWS disbursements.
Effect or Potential Effect – The Institute was not in compliance with FWS disbursement requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 40 pay periods selected for FWS testing, the amount of compensation disbursed to the student did not agree to the hours worked per the approved timesheet.
• For 4 of 40 pay periods selected for FWS testing, the students’ timesheet was not properly reviewed/approved by a supervisor as required.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and its internal controls to ensure that students receiving FWS compensation are paid timely, and for the correct amounts. Additionally, we recommend that student timesheets be approved prior to the disbursement of funds.
Views of Responsible Officials – The Institute agrees with the finding. Moving forward, when Student Employment payment information is entered into our Human Resource information system, the Institute will continuously check timecards to ensure that the wages match the number of hours students work. Furthermore, the Institute will stay in communication with student supervisors to ensure they are approving timecards before payroll is processed.
Finding 2024-003 – N. Special Tests and Provisions – Verification
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.007, #84.033, #84.063, #84.268)
Criteria or Specific Requirement – An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition – The Institute did not accurately verify all required information for a student.
Cause – Administrative oversight in internal controls over required verification procedures.
Effect or Potential Effect – The Institute was not in compliance with the verification requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 6 students selected for the Institute did not perform appropriate verification procedures including the verification of certain tax return information.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and internal controls to ensure appropriate verification procedures are performed for all students who are selected for verification.
Views of Responsible Officials – The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56).
The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified.
The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid.
Finding 2024-003 – N. Special Tests and Provisions – Verification
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.007, #84.033, #84.063, #84.268)
Criteria or Specific Requirement – An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition – The Institute did not accurately verify all required information for a student.
Cause – Administrative oversight in internal controls over required verification procedures.
Effect or Potential Effect – The Institute was not in compliance with the verification requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 6 students selected for the Institute did not perform appropriate verification procedures including the verification of certain tax return information.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and internal controls to ensure appropriate verification procedures are performed for all students who are selected for verification.
Views of Responsible Officials – The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56).
The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified.
The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid.
Finding 2024-003 – N. Special Tests and Provisions – Verification
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.007, #84.033, #84.063, #84.268)
Criteria or Specific Requirement – An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition – The Institute did not accurately verify all required information for a student.
Cause – Administrative oversight in internal controls over required verification procedures.
Effect or Potential Effect – The Institute was not in compliance with the verification requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 6 students selected for the Institute did not perform appropriate verification procedures including the verification of certain tax return information.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and internal controls to ensure appropriate verification procedures are performed for all students who are selected for verification.
Views of Responsible Officials – The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56).
The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified.
The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid.
Finding 2024-003 – N. Special Tests and Provisions – Verification
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.007, #84.033, #84.063, #84.268)
Criteria or Specific Requirement – An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition – The Institute did not accurately verify all required information for a student.
Cause – Administrative oversight in internal controls over required verification procedures.
Effect or Potential Effect – The Institute was not in compliance with the verification requirements.
Questioned Costs – Below reportable threshold.
Context:
• For 1 of 6 students selected for the Institute did not perform appropriate verification procedures including the verification of certain tax return information.
Indication of Repeat Finding – No similar finding noted in the prior year.
Recommendation – We recommend that the Institute enhance its procedures and internal controls to ensure appropriate verification procedures are performed for all students who are selected for verification.
Views of Responsible Officials – The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56).
The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified.
The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid.