Audit 56914

Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our audit we found two (2) of forty (40) students selected for testing whose changes in enrollment status were not accurately and timely transmitted to NSLDS. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Union College (the College) generally certifies its enrollment reports through rosters provided to the NSC. However, the College is still responsible for the timely reporting of all required enrollment changes to the NSLDS. Additionally, the reporting to NSLDS for each of these students was transmitted with the status of withdrawn, when the enrollment status was graduated. Cause For one student, there was concern about passing classes and the student applied for withdrawal right at the end of the semester. However, shortly thereafter, grades were finalized and it was determined the student had earned enough credits to graduate. Due to the two concurrent submissions of withdrawn and graduated, only the withdrawal was processed and the College did not identify the error on a timely basis. For the other student with an exception identified in our sample, there was a mid-stream change in Classification of Instructional Programs (CIP) code. The spring class of Economics students had a mid-stream change in CIP code resulting in issues with the NSC submission for impacted students since they were noted as withdrawn from their old CIP code and graduated with the updated code. Only the withdrawal was processed. In addition to the student selected in our sample, this impacted 33 additional students with federal loans in the spring Economics class.Further, we noted management?s internal controls are not designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 30 or 60 day time frame. The College should implement a review of the submitted enrollment changes to the NSLDS to ensure current student enrollment changes are accurately reflected, including specific review of status changes related to situations similar to those described above where the risk of error is higher. Any differences, including when any enrollment status changes are rejected by NSC or errors in status are processed, should be identified and investigated in a timely manner. Views of Responsible Officials Recommendation accepted. Refer to the corrective action plan for further details.

Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our audit we found two (2) of forty (40) students selected for testing whose changes in enrollment status were not accurately and timely transmitted to NSLDS. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Union College (the College) generally certifies its enrollment reports through rosters provided to the NSC. However, the College is still responsible for the timely reporting of all required enrollment changes to the NSLDS. Additionally, the reporting to NSLDS for each of these students was transmitted with the status of withdrawn, when the enrollment status was graduated. Cause For one student, there was concern about passing classes and the student applied for withdrawal right at the end of the semester. However, shortly thereafter, grades were finalized and it was determined the student had earned enough credits to graduate. Due to the two concurrent submissions of withdrawn and graduated, only the withdrawal was processed and the College did not identify the error on a timely basis. For the other student with an exception identified in our sample, there was a mid-stream change in Classification of Instructional Programs (CIP) code. The spring class of Economics students had a mid-stream change in CIP code resulting in issues with the NSC submission for impacted students since they were noted as withdrawn from their old CIP code and graduated with the updated code. Only the withdrawal was processed. In addition to the student selected in our sample, this impacted 33 additional students with federal loans in the spring Economics class.Further, we noted management?s internal controls are not designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 30 or 60 day time frame. The College should implement a review of the submitted enrollment changes to the NSLDS to ensure current student enrollment changes are accurately reflected, including specific review of status changes related to situations similar to those described above where the risk of error is higher. Any differences, including when any enrollment status changes are rejected by NSC or errors in status are processed, should be identified and investigated in a timely manner. Views of Responsible Officials Recommendation accepted. Refer to the corrective action plan for further details.