Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting (Noncompliance and Significant Deficiency)
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268
Criteria - Institutions are required to repo...
Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting (Noncompliance and Significant Deficiency)
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). 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 verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days.
Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended May 31, 2024. We obtained the student records and tested compliance with federal regulations for the specific loans and grants.
For 13 out of the 40 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60 day reporting window after the status change was effective.
For 7 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The University’s processes of internal controls for reporting enrollment information and to timely report student status changes to NSLDS were not adequate.
Effect - Enrollment reporting to NSLDS did not include accurate information.
Identification of Repeat Finding – Repeat finding of prior year finding 2023-001.
Student status changes were not reported to NSLDS within the required timeframe.
Recommendation - We recommend the University revise its processes for reporting student status changes to NSLDS. The University should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Out of the 20 exceptions included in this finding, 16 were properly and timely reported by the University to the third-party service provider. The University is currently working with their third-party service provider to identify the root cause of the untimely reporting.
Corrective Action Plan for Finding 2024-001 - The University provided additional training and monitoring to the employees involved in this process. Furthermore, the University engaged a former employee on a contractual basis to assist with the reporting process. The contract employee has significant experience in reporting information to the University’s third-party agent, National Student Clearinghouse (NSC), and to the National Student Loan Data System (NSLDS). The University is actively working with the Audit Resources team at NSC to revise our reporting processes and develop a reporting schedule that will more closely align with the University's calendar and eliminate the root cause of the data errors.