Finding - Special Tests and Provisions: Enrollment Reporting - Federal Direct Student Loans, Assistance Listing Number 84.268; June 30, 2022 Award Year, U.S. Department of Education Criteria or Specific Requirement Changes in enrollment to less than half time, graduated or withdrawn must be reported to National Student Loan Data System within 30 days. However, if a roster file is expected within 60 days of the status change, a school may provide the data on that roster file. Because enrollment changes must be reported within 30 days, or there is a chance that not all scheduled rosters will fulfill this requirement; ad hoc reporting can fulfill this requirement. (National Student Loan Data System Enrollment Reporting Guide, November 2020, page 6.) (34 CFR 682.610(c)(1)-(c)(2)) Condition and Context Of the three students within the sample of students tested that had status changes, all were reported to NSLDS outside of the required timeline, and two were reported to NSLDS inaccurately subsequent to the 2021-2022 fiscal year. Cause Due to a failure to follow controls, the requirement to submit status changes and roster information to the NSLDS was not met. As such, this information was not reported during the 2021-2022 fiscal year. Effect or Potential Effect The NSLDS System was not updated within the proper timeframe, thus the Seminary was out of compliance with the NSLDS reporting provisions. Questioned Costs None noted. Identification as a Repeat Finding This is a repeat finding. Recommendation We recommend procedures be implemented to include the review of scheduled submissions to NSLDS for the purpose of ensuring accurate reporting and identifying any time gaps that could violate reporting requirements. A Seminary representative should be tasked with reviewing all scheduled submissions to NSLDS. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
Finding - Special Tests and Provisions: Borrower Transmission Data - Federal Direct Student Loans, Assistance Listing Number 84.268. June 30, 2022 Award Year, U.S. Department of Education Criteria or Specific Requirement Colleges must report all loan disbursements and submit required records to the Direct Loan Servicing System (?DLSS?) via the Common Origination and Disbursement (?COD?) within 30 days of disbursement. Disbursement dates and amounts in the DLSS must be supported by the Seminary?s records (34 CFR sections 685.102(b), 685.301 and 303). The date of disbursement determines when a student becomes a federal student aid (?FSA?) recipient and has the rights and responsibilities of an FSA recipient. A disbursement occurs when the college credits a student?s account or pays a student or parent directly with: ? FSA program funds received from the Department; ? FSA program funds received from a Direct Loan lender, or ? Seminary funds labeled as FSA program funds in advance of receiving actual FSA program funds. (Student Financial Aid Handbook, Volume 4, Chapter 1, pages 4-9) Condition and Context Out of thirteen students selected for testing, one student had a date reported to COD outside of the required timeframe. Cause Due to staff turnover and a failure to follow controls, the Seminary did not report to COD with timely data following disbursement to student accounts. Effect or Potential Effect Delayed reporting of disbursement dates affect accurate administration of loan period start and end dates. Questioned Costs None noted. Identification as a Repeat Finding This is a repeat finding. Recommendation Following each disbursement, the Financial Aid Office should review and agree COD data to student accounts data to ensure accurate and timely reporting of borrower information. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
Finding - Special Tests and Provisions: Enrollment Reporting - Federal Direct Student Loans, Assistance Listing Number 84.268; June 30, 2022 Award Year, U.S. Department of Education Criteria or Specific Requirement Changes in enrollment to less than half time, graduated or withdrawn must be reported to National Student Loan Data System within 30 days. However, if a roster file is expected within 60 days of the status change, a school may provide the data on that roster file. Because enrollment changes must be reported within 30 days, or there is a chance that not all scheduled rosters will fulfill this requirement; ad hoc reporting can fulfill this requirement. (National Student Loan Data System Enrollment Reporting Guide, November 2020, page 6.) (34 CFR 682.610(c)(1)-(c)(2)) Condition and Context Of the three students within the sample of students tested that had status changes, all were reported to NSLDS outside of the required timeline, and two were reported to NSLDS inaccurately subsequent to the 2021-2022 fiscal year. Cause Due to a failure to follow controls, the requirement to submit status changes and roster information to the NSLDS was not met. As such, this information was not reported during the 2021-2022 fiscal year. Effect or Potential Effect The NSLDS System was not updated within the proper timeframe, thus the Seminary was out of compliance with the NSLDS reporting provisions. Questioned Costs None noted. Identification as a Repeat Finding This is a repeat finding. Recommendation We recommend procedures be implemented to include the review of scheduled submissions to NSLDS for the purpose of ensuring accurate reporting and identifying any time gaps that could violate reporting requirements. A Seminary representative should be tasked with reviewing all scheduled submissions to NSLDS. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
Finding - Special Tests and Provisions: Borrower Transmission Data - Federal Direct Student Loans, Assistance Listing Number 84.268. June 30, 2022 Award Year, U.S. Department of Education Criteria or Specific Requirement Colleges must report all loan disbursements and submit required records to the Direct Loan Servicing System (?DLSS?) via the Common Origination and Disbursement (?COD?) within 30 days of disbursement. Disbursement dates and amounts in the DLSS must be supported by the Seminary?s records (34 CFR sections 685.102(b), 685.301 and 303). The date of disbursement determines when a student becomes a federal student aid (?FSA?) recipient and has the rights and responsibilities of an FSA recipient. A disbursement occurs when the college credits a student?s account or pays a student or parent directly with: ? FSA program funds received from the Department; ? FSA program funds received from a Direct Loan lender, or ? Seminary funds labeled as FSA program funds in advance of receiving actual FSA program funds. (Student Financial Aid Handbook, Volume 4, Chapter 1, pages 4-9) Condition and Context Out of thirteen students selected for testing, one student had a date reported to COD outside of the required timeframe. Cause Due to staff turnover and a failure to follow controls, the Seminary did not report to COD with timely data following disbursement to student accounts. Effect or Potential Effect Delayed reporting of disbursement dates affect accurate administration of loan period start and end dates. Questioned Costs None noted. Identification as a Repeat Finding This is a repeat finding. Recommendation Following each disbursement, the Financial Aid Office should review and agree COD data to student accounts data to ensure accurate and timely reporting of borrower information. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.