Audit 9841

FY End
2023-06-30
Total Expended
$265.29M
Findings
4
Programs
104
Year: 2023 Accepted: 2024-01-05

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
7543 2023-001 - - N
7544 2023-001 - - N
583985 2023-001 - - N
583986 2023-001 - - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $86.90M Yes 1
84.063 Federal Pell Grant Program $20.46M Yes 1
84.038 Federal Perkins Loan Program $12.67M Yes 0
84.908 Covid-19 National Technical Institute of the Deaf $8.00M - 0
12.630 Basic, Applied, and Advanced Research in Science and Engineering $4.30M Yes 0
84.033 Federal Work-Study Program $2.00M Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $1.23M Yes 0
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $665,171 - 0
93.RD Centers for Medicare and Medicaid Services $662,742 - 0
12.905 Cybersecurity Core Curriculum $563,181 - 0
93.361 Nursing Research $523,015 - 0
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $496,817 - 0
45.312 National Leadership Grants $450,971 - 0
93.191 Graduate Psychology Education $448,033 - 0
12.RD U.s. Government $384,851 - 0
84.047 Trio Upward Bound $372,136 - 0
12.RD Army Material Command $357,539 - 0
84.908 Federal Appropriation $354,669 - 0
11.619 Arrangements for Interdisciplinary Research Infrastructure $302,592 - 0
93.732 Mental and Behavioral Health Education and Training Grants $298,004 - 0
15.808 U.s. Geological Survey Research and Data Collection $259,098 - 0
81.RD Department of Energy $255,773 - 0
84.217 Trio McNair Post-Baccalaureate Achievement $217,022 - 0
45.149 Promotion of the Humanities Division of Preservation and Access $179,742 - 0
93.395 Cancer Treatment Research $173,434 - 0
20.RD Federal Aviation Administration $166,440 - 0
12.431 Basic Scientific Research $164,752 - 0
19.040 Public Diplomacy Programs $156,702 - 0
98.002 Cooperative Development Program (cdp) $138,361 - 0
81.089 Fossil Energy Research and Development $138,247 - 0
93.837 Cardiovascular Diseases Research $135,116 - 0
12.RD National Reconnaissance Office $133,082 - 0
12.RD Department of the Navy, Office of the Chief of Naval Research $131,045 - 0
47.050 Geosciences $118,025 - 0
47.049 Mathematical and Physical Sciences $110,987 - 0
12.900 Language Grant Program $105,070 - 0
93.867 Vision Research $103,944 - 0
12.300 Basic and Applied Scientific Research $103,188 - 0
93.838 Lung Diseases Research $102,094 - 0
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $101,560 - 0
97.RD Department of Homeland Security $95,141 - 0
93.279 Drug Abuse and Addiction Research Programs $91,240 - 0
10.310 Agriculture and Food Research Initiative (afri) $85,001 - 0
43.012 Space Technology $83,163 - 0
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $81,484 - 0
16.609 Project Safe Neighborhoods $80,698 - 0
11.611 Manufacturing Extension Partnership $78,242 - 0
12.903 Gencyber Grants Program $76,387 - 0
93.396 Cancer Biology Research $74,762 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $72,683 - 0
19.124 East Asia and Pacific Grants Program $72,220 - 0
11.307 Economic Adjustment Assistance $68,118 Yes 0
93.839 Blood Diseases and Resources Research $60,174 - 0
47.070 Computer and Information Science and Engineering $56,595 - 0
93.859 Biomedical Research and Research Training $54,459 - 0
93.394 Cancer Detection and Diagnosis Research $51,465 - 0
20.109 Air Transportation Centers of Excellence $51,349 - 0
77.008 U.s. Nuclear Regulatory Commission Scholarship and Fellowship Program $51,243 - 0
11.999 Marine Debris Program $50,499 - 0
47.083 Integrative Activities $50,466 - 0
12.RD Advanced Research Projects Agency $49,277 - 0
10.664 Cooperative Forestry Assistance $48,497 - 0
66.717 Source Reduction Assistance $46,720 - 0
84.047 Department of Education - Office of Postsecondary Education $46,140 - 0
84.016 Undergraduate International Studies and Foreign Language Programs $43,615 - 0
93.575 Child Care and Development Block Grant $43,005 - 0
81.087 Renewable Energy Research and Development $41,639 - 0
43.001 Science $40,889 - 0
81.049 Office of Science Financial Assistance Program $40,222 - 0
11.417 Sea Grant Support $38,844 - 0
12.RD Army Materiel Command $36,686 - 0
12.800 Air Force Defense Research Sciences Program $36,100 - 0
11.620 Science, Technology, Business And/or Education Outreach $34,617 - 0
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $33,876 - 0
93.121 Oral Diseases and Disorders Research $27,999 - 0
12.RD Department of the Air Force, Materiel Command $27,606 - 0
81.112 Stewardship Science Grant Program $26,504 - 0
47.079 Office of International Science and Engineering $25,937 - 0
47.075 Social, Behavioral, and Economic Sciences $24,533 - 0
93.865 Child Health and Human Development Extramural Research $23,418 - 0
12.RD National Security Agency $22,914 - 0
10.707 Research Joint Venture and Cost Reimbursable Agreements $22,223 - 0
45.024 Promotion of the Arts Grants to Organizations and Individuals $20,000 - 0
64.RD Department of Veteran Affairs $19,886 - 0
93.173 Research Related to Deafness and Communication Disorders $19,879 - 0
47.074 Biological Sciences $18,327 - 0
47.076 Stem Education (formerly Education and Human Resources) $18,057 - 0
10.762 Solid Waste Management Grants $17,956 - 0
93.273 Alcohol Research Programs $16,962 - 0
12.420 Military Medical Research and Development $16,950 - 0
43.008 Office of Stem Engagement (ostem) $15,000 - 0
12.RD Department of Defense $14,240 - 0
43.003 Exploration $13,405 - 0
47.041 Engineering $13,339 - 0
43.RD National Aeronautics and Space Administration $11,539 - 0
47.084 Nsf Technology, Innovation, and Partnerships $9,459 - 0
12.910 Research and Technology Development $9,388 - 0
93.855 Allergy and Infectious Diseases Research $8,831 - 0
20.205 Highway Planning and Construction $8,818 - 0
45.169 Promotion of the Humanities Office of Digital Humanities $3,181 - 0
19.929 Save America's Treasures $2,147 - 0
93.879 Medical Library Assistance $979 - 0
11.429 Marine Sanctuary Program $75 - 0
84.425 Covid-19 Higher Education Emergency Relief Fund (heerf) - Student Portion $-265 - 0

Contacts

Name Title Type
J6TWTRKC1X14 Milagros Concepcion Auditee
5854755428 Keith Belote Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (Schedule) includes the expenditures of Rochester Institute of Technology (the “University”) under programs of the federal government and is presented on the accrual basis of accounting. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Negative amounts represent current year adjustments of amounts reported in prior years. The University applies its predetermined approved facilities and administrative rate when charging indirect costs to federal awards rather than the 10% de minimis cost rate as described in Section 200.414 of the Uniform Guidance. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between the University and the agencies and departments of the federal government, or passed-through by other organizations to the University from agencies and departments of the federal government. When available, Assistance Listing Numbers and pass-through numbers are provided. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University. De Minimis Rate Used: N Rate Explanation: RIT has Federal Agency Acceptance of Negotiated Indirect Cost Rates The accompanying Schedule of Expenditures of Federal Awards (Schedule) includes the expenditures of Rochester Institute of Technology (the “University”) under programs of the federal government and is presented on the accrual basis of accounting. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Negative amounts represent current year adjustments of amounts reported in prior years. The University applies its predetermined approved facilities and administrative rate when charging indirect costs to federal awards rather than the 10% de minimis cost rate as described in Section 200.414 of the Uniform Guidance. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between the University and the agencies and departments of the federal government, or passed-through by other organizations to the University from agencies and departments of the federal government. When available, Assistance Listing Numbers and pass-through numbers are provided. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University.
Title: Federally Guaranteed Loans Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (Schedule) includes the expenditures of Rochester Institute of Technology (the “University”) under programs of the federal government and is presented on the accrual basis of accounting. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Negative amounts represent current year adjustments of amounts reported in prior years. The University applies its predetermined approved facilities and administrative rate when charging indirect costs to federal awards rather than the 10% de minimis cost rate as described in Section 200.414 of the Uniform Guidance. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between the University and the agencies and departments of the federal government, or passed-through by other organizations to the University from agencies and departments of the federal government. When available, Assistance Listing Numbers and pass-through numbers are provided. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University. De Minimis Rate Used: N Rate Explanation: RIT has Federal Agency Acceptance of Negotiated Indirect Cost Rates The University participated in the Federal Perkins Loan Program through its expiration on September 30, 2017. The balance in this program, $8,054,556 at June 30, 2023, as well as loan expenditures and disbursements are federally guaranteed. The University is responsible for certain administrative duties only with respect to the Federal Direct Loan program and, accordingly, these loans are not included in the University’s consolidated financial statements. It is not practical to determine the balance of loans outstanding under these programs at June 30, 2023.
Title: National Technical Institute for the Deaf (“NTID”, “College”) Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (Schedule) includes the expenditures of Rochester Institute of Technology (the “University”) under programs of the federal government and is presented on the accrual basis of accounting. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Negative amounts represent current year adjustments of amounts reported in prior years. The University applies its predetermined approved facilities and administrative rate when charging indirect costs to federal awards rather than the 10% de minimis cost rate as described in Section 200.414 of the Uniform Guidance. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between the University and the agencies and departments of the federal government, or passed-through by other organizations to the University from agencies and departments of the federal government. When available, Assistance Listing Numbers and pass-through numbers are provided. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University. De Minimis Rate Used: N Rate Explanation: RIT has Federal Agency Acceptance of Negotiated Indirect Cost Rates NTID was created on June 8, 1965 through Public Law 89-36, The National Technical Institute for the Deaf Act (now incorporated into Public Law 99-371, The Education of the Deaf Act (“EDA”) of 1986 and subsequently modified by the 1992, 1993 and 1999 Amendments). In March 1966, the Policies, Guidelines, and Application Procedures were prepared by the National Advisory Board through the auspices of the Secretary of Health, Education and Welfare. This document provided a framework for the character and composition of NTID by establishing specific goals, a program for instruction, procedures for admission, placement provisions and facilities requirements. After an extensive search for the appropriate "Host Institution," the Agreement for Establishment and Operation of the National Technical Institute for the Deaf between the Secretary of Health, Education and Welfare and Rochester Institute of Technology, was signed on December 20, 1966. These four documents are in essence the law and collectively provide the overall guidance on the expenditure of federal funds. NTID is a unique federal program in that its funding must be approved through an annual appropriation by the United States Congress. The appropriation currently covers approximately 81% of the College’s total operating costs and provides matching funds for the University’s Federal Endowment Fund. The remaining operating costs are funded by other sources of income including tuition, room, board and fees paid by students and a program of private fundraising as required by law. In addition to offering a wide array of academic programs to deaf and hard-of-hearing students, the College promotes and disseminates its services and its research findings nationally and internationally; educates other professionals to serve people who are deaf and hard-of-hearing; and, interacts regularly with its federal oversight agencies. As a result, there are a number of activities whose costs are treated as direct and others that are treated as indirect, where costs have been incurred for common or joint objectives and cannot be readily identified with a particular cost objective. The operation of NTID in conjunction with the overall congressional appropriation process does not result in finalization of the program results until after completion of the indirect cost recovery process negotiated annually by the University with the Cost Allocation Services of the Department of Health and Human Services. For the year ended June 30, 2023, the Policies, Guidelines, and Application Procedures for NTID, promulgated by the Department of Health and Human Services, and the EDA as amended, govern the allowability of expenditures related to NTID. NTID is not subject to 2 CFR Part 200, Subpart E in the determination of the allowability of costs, but rather is subject to the provisions of the four authorizing documents as described above, with particular emphasis on the Cost Principles as stated in the EDA, as amended. The principles and policies employed by the University in determining costs applicable to NTID encompass the concepts of reasonableness of cost, necessity for the operation of NTID, prudence, cost-benefit, and allowability; University policies; and, the EDA. Direct costs are those costs that are identified with activities of the College with relative ease and a high degree of accuracy. After direct costs have been determined and assigned to awards or other work as appropriate, indirect costs are those remaining to be allocated to benefiting cost objectives, net of costs of certain activities not allowable as charges to NTID. The allocation of indirect costs to NTID is designed to reflect an equitable distribution of those allowable costs indirectly benefiting all of the colleges which comprise the University. In addition, NTID received funds in its annual appropriation to support a regional partnership with the Alabama Institute for the Deaf and Blind (“AIDB”). The NTID Southeast Regional STEM Center was established to expand the geographic reach of activities and services supported by NTID consistent with its mission and strategic plan. Of the amount included in government grants and contracts on the Consolidated Statements of Activities, $10,058,583 and $6,465,818 at June 30, 2023 and 2022, respectively, was appropriated for the AIDB regional partnership.
Title: NTID Program Expenditures Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (Schedule) includes the expenditures of Rochester Institute of Technology (the “University”) under programs of the federal government and is presented on the accrual basis of accounting. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Negative amounts represent current year adjustments of amounts reported in prior years. The University applies its predetermined approved facilities and administrative rate when charging indirect costs to federal awards rather than the 10% de minimis cost rate as described in Section 200.414 of the Uniform Guidance. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between the University and the agencies and departments of the federal government, or passed-through by other organizations to the University from agencies and departments of the federal government. When available, Assistance Listing Numbers and pass-through numbers are provided. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University. De Minimis Rate Used: N Rate Explanation: RIT has Federal Agency Acceptance of Negotiated Indirect Cost Rates NTID program expenditures for the year ended June 30, 2023 were $115,077,969, of which $92,961,239 represents direct and indirect costs charged to the federal government. (see table in note)
Title: Federal Emergency Management Agency (FEMA) Expenditures Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (Schedule) includes the expenditures of Rochester Institute of Technology (the “University”) under programs of the federal government and is presented on the accrual basis of accounting. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Negative amounts represent current year adjustments of amounts reported in prior years. The University applies its predetermined approved facilities and administrative rate when charging indirect costs to federal awards rather than the 10% de minimis cost rate as described in Section 200.414 of the Uniform Guidance. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between the University and the agencies and departments of the federal government, or passed-through by other organizations to the University from agencies and departments of the federal government. When available, Assistance Listing Numbers and pass-through numbers are provided. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University. De Minimis Rate Used: N Rate Explanation: RIT has Federal Agency Acceptance of Negotiated Indirect Cost Rates As of June 30, 2023, the University received approval for $674,327 of claims submitted to FEMA during the year ended June 30, 2023 under Assistance Listing Number 97.036. The claims submitted represented incurred expenses attributed to the University’s response to COVID-19. The Schedule of Expenditures of Federal Awards for the year ended June 30, 2023 includes expenses of $674,327 which were incurred in a prior fiscal year.

Finding Details

2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2022 - 6/30/2023 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through the NSLDS. The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the institution in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student who received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had 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, the institution must report the change within 60 days from which the change was identified. Condition: We reviewed a sample of twenty-five students enrolled at the University who received either Pell and/or Direct Loans and had a change of enrollment status during the periods of time July 1, 2022 through July 18, 2022 and March 1, 2023 through June 30, 2023 of the fiscal year. Of the twenty-five students tested, nine students were not reported within the 60-day reporting timeframe. For seven of the students tested, the change in enrollment was reported to the NSLDS between 87 and 161 days from the date the change was identified. For two of the students tested, the change in enrollment was reported to the National Student Clearinghouse (NSC) for upload to the NSLDS however the student status has not yet been updated within the NSLDS records. Cause: There were three causes identified from the condition:  For four students, who each changed status during the spring semester and were not planning on returning in the fall semester, the University identified student status changes at the end of the spring semester, however waited until the beginning of the fall semester to communicate these changes to the NSC through their fall enrollment data submission rather than manually communicating them to the NSC upon identification;  For three students, who were each subject to a late degree certification, the University’s internal verification process was not adequately designed to meet the NSC’s two-step verification process to ensure that graduation status was timely updated to the NSC; and  For two students, the student status changes were timely reported to the NSC, however were not reported by NSC to the NSLDS. The University does not have an internal process in place to verify all student status changes communicated to the NSC are completely, accurately and timely communicated to the NSLDS. Effect: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by late reporting. Recommendation: We recommend the University perform the following:  Increase the frequency in which it reports enrollment updates to the NSC throughout the summer semester to allow for enrollment changes to be received by the NSLDS in a timely manner;  Enhance the University’s degree verification process for late certifications to include the two steps now required by the NSC which will ensure the status change of all graduates are timely communicated to the NSC and ultimately reported to the NSLDS; and  Implement a periodic reconciliation process between the NSC and the NSLDS to verify that the NSLDS timely and completely received communication of all student status changes. Additionally, the University should discuss this matter with the NSC and the NSLDS to understand why the student status changes were not communicated to the NSLDS and determine if additional action can be taken by the University to ensure these status changes are updated.
2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2022 - 6/30/2023 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through the NSLDS. The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the institution in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student who received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had 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, the institution must report the change within 60 days from which the change was identified. Condition: We reviewed a sample of twenty-five students enrolled at the University who received either Pell and/or Direct Loans and had a change of enrollment status during the periods of time July 1, 2022 through July 18, 2022 and March 1, 2023 through June 30, 2023 of the fiscal year. Of the twenty-five students tested, nine students were not reported within the 60-day reporting timeframe. For seven of the students tested, the change in enrollment was reported to the NSLDS between 87 and 161 days from the date the change was identified. For two of the students tested, the change in enrollment was reported to the National Student Clearinghouse (NSC) for upload to the NSLDS however the student status has not yet been updated within the NSLDS records. Cause: There were three causes identified from the condition:  For four students, who each changed status during the spring semester and were not planning on returning in the fall semester, the University identified student status changes at the end of the spring semester, however waited until the beginning of the fall semester to communicate these changes to the NSC through their fall enrollment data submission rather than manually communicating them to the NSC upon identification;  For three students, who were each subject to a late degree certification, the University’s internal verification process was not adequately designed to meet the NSC’s two-step verification process to ensure that graduation status was timely updated to the NSC; and  For two students, the student status changes were timely reported to the NSC, however were not reported by NSC to the NSLDS. The University does not have an internal process in place to verify all student status changes communicated to the NSC are completely, accurately and timely communicated to the NSLDS. Effect: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by late reporting. Recommendation: We recommend the University perform the following:  Increase the frequency in which it reports enrollment updates to the NSC throughout the summer semester to allow for enrollment changes to be received by the NSLDS in a timely manner;  Enhance the University’s degree verification process for late certifications to include the two steps now required by the NSC which will ensure the status change of all graduates are timely communicated to the NSC and ultimately reported to the NSLDS; and  Implement a periodic reconciliation process between the NSC and the NSLDS to verify that the NSLDS timely and completely received communication of all student status changes. Additionally, the University should discuss this matter with the NSC and the NSLDS to understand why the student status changes were not communicated to the NSLDS and determine if additional action can be taken by the University to ensure these status changes are updated.
2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2022 - 6/30/2023 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through the NSLDS. The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the institution in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student who received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had 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, the institution must report the change within 60 days from which the change was identified. Condition: We reviewed a sample of twenty-five students enrolled at the University who received either Pell and/or Direct Loans and had a change of enrollment status during the periods of time July 1, 2022 through July 18, 2022 and March 1, 2023 through June 30, 2023 of the fiscal year. Of the twenty-five students tested, nine students were not reported within the 60-day reporting timeframe. For seven of the students tested, the change in enrollment was reported to the NSLDS between 87 and 161 days from the date the change was identified. For two of the students tested, the change in enrollment was reported to the National Student Clearinghouse (NSC) for upload to the NSLDS however the student status has not yet been updated within the NSLDS records. Cause: There were three causes identified from the condition:  For four students, who each changed status during the spring semester and were not planning on returning in the fall semester, the University identified student status changes at the end of the spring semester, however waited until the beginning of the fall semester to communicate these changes to the NSC through their fall enrollment data submission rather than manually communicating them to the NSC upon identification;  For three students, who were each subject to a late degree certification, the University’s internal verification process was not adequately designed to meet the NSC’s two-step verification process to ensure that graduation status was timely updated to the NSC; and  For two students, the student status changes were timely reported to the NSC, however were not reported by NSC to the NSLDS. The University does not have an internal process in place to verify all student status changes communicated to the NSC are completely, accurately and timely communicated to the NSLDS. Effect: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by late reporting. Recommendation: We recommend the University perform the following:  Increase the frequency in which it reports enrollment updates to the NSC throughout the summer semester to allow for enrollment changes to be received by the NSLDS in a timely manner;  Enhance the University’s degree verification process for late certifications to include the two steps now required by the NSC which will ensure the status change of all graduates are timely communicated to the NSC and ultimately reported to the NSLDS; and  Implement a periodic reconciliation process between the NSC and the NSLDS to verify that the NSLDS timely and completely received communication of all student status changes. Additionally, the University should discuss this matter with the NSC and the NSLDS to understand why the student status changes were not communicated to the NSLDS and determine if additional action can be taken by the University to ensure these status changes are updated.
2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2022 - 6/30/2023 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through the NSLDS. The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the institution in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student who received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had 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, the institution must report the change within 60 days from which the change was identified. Condition: We reviewed a sample of twenty-five students enrolled at the University who received either Pell and/or Direct Loans and had a change of enrollment status during the periods of time July 1, 2022 through July 18, 2022 and March 1, 2023 through June 30, 2023 of the fiscal year. Of the twenty-five students tested, nine students were not reported within the 60-day reporting timeframe. For seven of the students tested, the change in enrollment was reported to the NSLDS between 87 and 161 days from the date the change was identified. For two of the students tested, the change in enrollment was reported to the National Student Clearinghouse (NSC) for upload to the NSLDS however the student status has not yet been updated within the NSLDS records. Cause: There were three causes identified from the condition:  For four students, who each changed status during the spring semester and were not planning on returning in the fall semester, the University identified student status changes at the end of the spring semester, however waited until the beginning of the fall semester to communicate these changes to the NSC through their fall enrollment data submission rather than manually communicating them to the NSC upon identification;  For three students, who were each subject to a late degree certification, the University’s internal verification process was not adequately designed to meet the NSC’s two-step verification process to ensure that graduation status was timely updated to the NSC; and  For two students, the student status changes were timely reported to the NSC, however were not reported by NSC to the NSLDS. The University does not have an internal process in place to verify all student status changes communicated to the NSC are completely, accurately and timely communicated to the NSLDS. Effect: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by late reporting. Recommendation: We recommend the University perform the following:  Increase the frequency in which it reports enrollment updates to the NSC throughout the summer semester to allow for enrollment changes to be received by the NSLDS in a timely manner;  Enhance the University’s degree verification process for late certifications to include the two steps now required by the NSC which will ensure the status change of all graduates are timely communicated to the NSC and ultimately reported to the NSLDS; and  Implement a periodic reconciliation process between the NSC and the NSLDS to verify that the NSLDS timely and completely received communication of all student status changes. Additionally, the University should discuss this matter with the NSC and the NSLDS to understand why the student status changes were not communicated to the NSLDS and determine if additional action can be taken by the University to ensure these status changes are updated.