2024 001 Special Tests and Provisions (Verification)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student’s output documents.
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
For two of the nineteen students selected for verification in fiscal year 2024, the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification for the V4 verification status.
There were a total of ninety-nine students in fiscal year 2024 selected for V4 or V5 verification and required to submit a Statement of Educational Purpose. The University performed an analysis to determine the total number of students impacted by this issue. There were a total of four students (including the two students mentioned in this finding) for which the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification.
Cause:
The University incorrectly coded high school completion documents as the Statement of Educational Purpose for these two students and therefore did not properly obtain a signed Statement of Educational Purpose to properly complete verification. The management review control over the verification process did not operate at a precise enough level to identify miscoding of the high school completion documents.
Effect:
The verification was not properly completed for these students.
Questioned Costs:
None, as the students were ultimately awarded and disbursed the correct amount of student financial aid.
Recommendation:
We recommend the University ensure that it follows its current policies and procedures to ensure that the proper documentation is requested and completed for the student as required for the verification status.
Views of Responsible Officials:
The University acknowledges that it incorrectly coded other documents as the Statement of Educational Purpose for the two students selected and therefore did not obtain a signed Statement of Educational Purpose to properly complete verification. The University has enhanced its report for required verification documentation to highlight those selected with V4 or V5 status to ensure all proper documentation is requested and provided by the students as required for the verification status. The review will be done on a monthly basis throughout the fiscal year.
2024 001 Special Tests and Provisions (Verification)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student’s output documents.
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
For two of the nineteen students selected for verification in fiscal year 2024, the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification for the V4 verification status.
There were a total of ninety-nine students in fiscal year 2024 selected for V4 or V5 verification and required to submit a Statement of Educational Purpose. The University performed an analysis to determine the total number of students impacted by this issue. There were a total of four students (including the two students mentioned in this finding) for which the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification.
Cause:
The University incorrectly coded high school completion documents as the Statement of Educational Purpose for these two students and therefore did not properly obtain a signed Statement of Educational Purpose to properly complete verification. The management review control over the verification process did not operate at a precise enough level to identify miscoding of the high school completion documents.
Effect:
The verification was not properly completed for these students.
Questioned Costs:
None, as the students were ultimately awarded and disbursed the correct amount of student financial aid.
Recommendation:
We recommend the University ensure that it follows its current policies and procedures to ensure that the proper documentation is requested and completed for the student as required for the verification status.
Views of Responsible Officials:
The University acknowledges that it incorrectly coded other documents as the Statement of Educational Purpose for the two students selected and therefore did not obtain a signed Statement of Educational Purpose to properly complete verification. The University has enhanced its report for required verification documentation to highlight those selected with V4 or V5 status to ensure all proper documentation is requested and provided by the students as required for the verification status. The review will be done on a monthly basis throughout the fiscal year.
2024 002 Special Tests and Provisions (Enrollment Reporting)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035). 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information.
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. Institutions are responsible for accurately reporting all Campus Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• OPEID number, enrollment effective date, enrollment status and certification date
Institutions are responsible for accurately reporting all Program Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date
Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845 0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)).
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS.
For five of forty students selected for testwork, the University did not report the student’s status as graduated within the Campus-Level Record or Program-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination.
For one of forty students selected for testwork, the University did not report the student’s status as graduated within the Program-Level Record. The graduation status was properly reported in the Campus-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination.
Cause:
The submission of certain student records was rejected by NSLDS in Summer 2024. Due to the volume of records rejected, the University needed time to resolve all errors and resubmit the rosters. During this process, the submission of the graduation information for the above individuals was missed. The management review control over the submission of the enrollment roster file did not operate at a precise enough level to identify the missing graduation information.
Effect:
Student status changes not reported in a timely manner could cause the student to not enter into repayment status on a timely basis. However, in this case, the student’s’ timely reported withdrawn status did cause the student to enter repayment status on a timely basis.
Questioned Costs:
None.
Recommendation:
We recommend the University enhance its current policies and procedures to ensure that when there are error codes generated from rejected NSLDS records that all student status changes are properly and timely reported to NSLDS when determined.
Views of Responsible Officials:
The University agrees with this finding. It is important to note that all six students were correctly reported with withdrawn status timely, and there was no delay of the students going into repayment status timely.
The University has communicated extensively with the Clearinghouse about these six errors which are related to Error Code 75. The Clearinghouse has been working with NSLDS about the issues in these particular cases as they are not only related to the University. It is the University’s understanding that the errors were caused by a technical issue with the NSLDS system modernization and were out of the University’s ability to remedy. The University believes that the issue causing these errors is resolved and continues to monitor NSLDS’ error reports on the Student Status Confirmation Reports (SSCR) to ensure we are aware if they return. The University will continue to submit the SSCR responses to the Clearinghouse and ensure we report individual graduations or enrollment if there are error codes that cannot be resolved timely through the Clearinghouse process.
2024 002 Special Tests and Provisions (Enrollment Reporting)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035). 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information.
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. Institutions are responsible for accurately reporting all Campus Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• OPEID number, enrollment effective date, enrollment status and certification date
Institutions are responsible for accurately reporting all Program Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date
Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845 0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)).
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS.
For five of forty students selected for testwork, the University did not report the student’s status as graduated within the Campus-Level Record or Program-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination.
For one of forty students selected for testwork, the University did not report the student’s status as graduated within the Program-Level Record. The graduation status was properly reported in the Campus-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination.
Cause:
The submission of certain student records was rejected by NSLDS in Summer 2024. Due to the volume of records rejected, the University needed time to resolve all errors and resubmit the rosters. During this process, the submission of the graduation information for the above individuals was missed. The management review control over the submission of the enrollment roster file did not operate at a precise enough level to identify the missing graduation information.
Effect:
Student status changes not reported in a timely manner could cause the student to not enter into repayment status on a timely basis. However, in this case, the student’s’ timely reported withdrawn status did cause the student to enter repayment status on a timely basis.
Questioned Costs:
None.
Recommendation:
We recommend the University enhance its current policies and procedures to ensure that when there are error codes generated from rejected NSLDS records that all student status changes are properly and timely reported to NSLDS when determined.
Views of Responsible Officials:
The University agrees with this finding. It is important to note that all six students were correctly reported with withdrawn status timely, and there was no delay of the students going into repayment status timely.
The University has communicated extensively with the Clearinghouse about these six errors which are related to Error Code 75. The Clearinghouse has been working with NSLDS about the issues in these particular cases as they are not only related to the University. It is the University’s understanding that the errors were caused by a technical issue with the NSLDS system modernization and were out of the University’s ability to remedy. The University believes that the issue causing these errors is resolved and continues to monitor NSLDS’ error reports on the Student Status Confirmation Reports (SSCR) to ensure we are aware if they return. The University will continue to submit the SSCR responses to the Clearinghouse and ensure we report individual graduations or enrollment if there are error codes that cannot be resolved timely through the Clearinghouse process.
2024 001 Special Tests and Provisions (Verification)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student’s output documents.
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
For two of the nineteen students selected for verification in fiscal year 2024, the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification for the V4 verification status.
There were a total of ninety-nine students in fiscal year 2024 selected for V4 or V5 verification and required to submit a Statement of Educational Purpose. The University performed an analysis to determine the total number of students impacted by this issue. There were a total of four students (including the two students mentioned in this finding) for which the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification.
Cause:
The University incorrectly coded high school completion documents as the Statement of Educational Purpose for these two students and therefore did not properly obtain a signed Statement of Educational Purpose to properly complete verification. The management review control over the verification process did not operate at a precise enough level to identify miscoding of the high school completion documents.
Effect:
The verification was not properly completed for these students.
Questioned Costs:
None, as the students were ultimately awarded and disbursed the correct amount of student financial aid.
Recommendation:
We recommend the University ensure that it follows its current policies and procedures to ensure that the proper documentation is requested and completed for the student as required for the verification status.
Views of Responsible Officials:
The University acknowledges that it incorrectly coded other documents as the Statement of Educational Purpose for the two students selected and therefore did not obtain a signed Statement of Educational Purpose to properly complete verification. The University has enhanced its report for required verification documentation to highlight those selected with V4 or V5 status to ensure all proper documentation is requested and provided by the students as required for the verification status. The review will be done on a monthly basis throughout the fiscal year.
2024 001 Special Tests and Provisions (Verification)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student’s output documents.
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
For two of the nineteen students selected for verification in fiscal year 2024, the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification for the V4 verification status.
There were a total of ninety-nine students in fiscal year 2024 selected for V4 or V5 verification and required to submit a Statement of Educational Purpose. The University performed an analysis to determine the total number of students impacted by this issue. There were a total of four students (including the two students mentioned in this finding) for which the University did not obtain the required Statement of Educational Purpose from the student in order to properly complete verification.
Cause:
The University incorrectly coded high school completion documents as the Statement of Educational Purpose for these two students and therefore did not properly obtain a signed Statement of Educational Purpose to properly complete verification. The management review control over the verification process did not operate at a precise enough level to identify miscoding of the high school completion documents.
Effect:
The verification was not properly completed for these students.
Questioned Costs:
None, as the students were ultimately awarded and disbursed the correct amount of student financial aid.
Recommendation:
We recommend the University ensure that it follows its current policies and procedures to ensure that the proper documentation is requested and completed for the student as required for the verification status.
Views of Responsible Officials:
The University acknowledges that it incorrectly coded other documents as the Statement of Educational Purpose for the two students selected and therefore did not obtain a signed Statement of Educational Purpose to properly complete verification. The University has enhanced its report for required verification documentation to highlight those selected with V4 or V5 status to ensure all proper documentation is requested and provided by the students as required for the verification status. The review will be done on a monthly basis throughout the fiscal year.
2024 002 Special Tests and Provisions (Enrollment Reporting)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035). 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information.
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. Institutions are responsible for accurately reporting all Campus Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• OPEID number, enrollment effective date, enrollment status and certification date
Institutions are responsible for accurately reporting all Program Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date
Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845 0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)).
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS.
For five of forty students selected for testwork, the University did not report the student’s status as graduated within the Campus-Level Record or Program-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination.
For one of forty students selected for testwork, the University did not report the student’s status as graduated within the Program-Level Record. The graduation status was properly reported in the Campus-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination.
Cause:
The submission of certain student records was rejected by NSLDS in Summer 2024. Due to the volume of records rejected, the University needed time to resolve all errors and resubmit the rosters. During this process, the submission of the graduation information for the above individuals was missed. The management review control over the submission of the enrollment roster file did not operate at a precise enough level to identify the missing graduation information.
Effect:
Student status changes not reported in a timely manner could cause the student to not enter into repayment status on a timely basis. However, in this case, the student’s’ timely reported withdrawn status did cause the student to enter repayment status on a timely basis.
Questioned Costs:
None.
Recommendation:
We recommend the University enhance its current policies and procedures to ensure that when there are error codes generated from rejected NSLDS records that all student status changes are properly and timely reported to NSLDS when determined.
Views of Responsible Officials:
The University agrees with this finding. It is important to note that all six students were correctly reported with withdrawn status timely, and there was no delay of the students going into repayment status timely.
The University has communicated extensively with the Clearinghouse about these six errors which are related to Error Code 75. The Clearinghouse has been working with NSLDS about the issues in these particular cases as they are not only related to the University. It is the University’s understanding that the errors were caused by a technical issue with the NSLDS system modernization and were out of the University’s ability to remedy. The University believes that the issue causing these errors is resolved and continues to monitor NSLDS’ error reports on the Student Status Confirmation Reports (SSCR) to ensure we are aware if they return. The University will continue to submit the SSCR responses to the Clearinghouse and ensure we report individual graduations or enrollment if there are error codes that cannot be resolved timely through the Clearinghouse process.
2024 002 Special Tests and Provisions (Enrollment Reporting)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Pell Grant Program (ALN 84.063)
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: Not a repeat finding.
Finding Type: Significant Deficiency and Noncompliance
Criteria:
Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035). 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information.
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. Institutions are responsible for accurately reporting all Campus Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• OPEID number, enrollment effective date, enrollment status and certification date
Institutions are responsible for accurately reporting all Program Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date
Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845 0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)).
Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS.
For five of forty students selected for testwork, the University did not report the student’s status as graduated within the Campus-Level Record or Program-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination.
For one of forty students selected for testwork, the University did not report the student’s status as graduated within the Program-Level Record. The graduation status was properly reported in the Campus-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination.
Cause:
The submission of certain student records was rejected by NSLDS in Summer 2024. Due to the volume of records rejected, the University needed time to resolve all errors and resubmit the rosters. During this process, the submission of the graduation information for the above individuals was missed. The management review control over the submission of the enrollment roster file did not operate at a precise enough level to identify the missing graduation information.
Effect:
Student status changes not reported in a timely manner could cause the student to not enter into repayment status on a timely basis. However, in this case, the student’s’ timely reported withdrawn status did cause the student to enter repayment status on a timely basis.
Questioned Costs:
None.
Recommendation:
We recommend the University enhance its current policies and procedures to ensure that when there are error codes generated from rejected NSLDS records that all student status changes are properly and timely reported to NSLDS when determined.
Views of Responsible Officials:
The University agrees with this finding. It is important to note that all six students were correctly reported with withdrawn status timely, and there was no delay of the students going into repayment status timely.
The University has communicated extensively with the Clearinghouse about these six errors which are related to Error Code 75. The Clearinghouse has been working with NSLDS about the issues in these particular cases as they are not only related to the University. It is the University’s understanding that the errors were caused by a technical issue with the NSLDS system modernization and were out of the University’s ability to remedy. The University believes that the issue causing these errors is resolved and continues to monitor NSLDS’ error reports on the Student Status Confirmation Reports (SSCR) to ensure we are aware if they return. The University will continue to submit the SSCR responses to the Clearinghouse and ensure we report individual graduations or enrollment if there are error codes that cannot be resolved timely through the Clearinghouse process.