Finding 10249 (2023-007)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-01-26
Audit: 13897
Organization: Heritage University (WA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The University has a significant deficiency in internal controls over compliance, leading to incomplete and inaccurate enrollment reporting to NSLDS.
  • Impacted Requirements: Institutions must report student attendance changes to NSLDS within 60 days, ensuring accuracy in high-risk data elements like program status and effective dates.
  • Recommended Follow-Up: Enhance policies for timely reporting of student status changes and establish a formal internal monitoring system for regular checks on NSLDS submissions.

Finding Text

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P222403, P268K232403 Award Year: 2022-23, 2021-22 Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – We selected a sample of 42 students out of a population of 626 who had received Federal aid and were reported to NSLDS during the fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University’s records. We noted exceptions with 4 out of the 42 students tested. Two students were not reported as withdrawn to NSLDS. One student was not reported as graduated to NSLDS. One student was reported to NSLDS, however the dates did not match the institutional records. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and oversight of the process. This resulted in incomplete and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding – Yes, 2022-010   Recommendation – We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Views of responsible officials and planned corrective actions – The University will adhere to current regulations and improve them if necessary to guarantee that all student status changes are recognized promptly and filed correctly within the allotted period. In order to internally audit the National Student Clearinghouse submissions, the University established a formal internal monitoring system wherein a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS.

Categories

Student Financial Aid Reporting Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 10234 2023-002
    Material Weakness Repeat
  • 10235 2023-002
    Material Weakness Repeat
  • 10236 2023-002
    Material Weakness Repeat
  • 10237 2023-003
    Significant Deficiency Repeat
  • 10238 2023-003
    Significant Deficiency Repeat
  • 10239 2023-004
    Material Weakness Repeat
  • 10240 2023-004
    Material Weakness Repeat
  • 10241 2023-004
    Material Weakness Repeat
  • 10242 2023-005
    Significant Deficiency Repeat
  • 10243 2023-005
    Significant Deficiency Repeat
  • 10244 2023-005
    Significant Deficiency Repeat
  • 10245 2023-006
    Material Weakness Repeat
  • 10246 2023-006
    Material Weakness Repeat
  • 10247 2023-006
    Material Weakness Repeat
  • 10248 2023-007
    Significant Deficiency Repeat
  • 10250 2023-008
    Material Weakness
  • 10251 2023-008
    Material Weakness
  • 10252 2023-008
    Material Weakness
  • 10253 2023-009
    Significant Deficiency
  • 10254 2023-009
    Significant Deficiency
  • 10255 2023-009
    Significant Deficiency
  • 10256 2023-009
    Significant Deficiency
  • 10257 2023-005
    Significant Deficiency Repeat
  • 10258 2023-005
    Significant Deficiency Repeat
  • 10259 2023-010
    Significant Deficiency
  • 586676 2023-002
    Material Weakness Repeat
  • 586677 2023-002
    Material Weakness Repeat
  • 586678 2023-002
    Material Weakness Repeat
  • 586679 2023-003
    Significant Deficiency Repeat
  • 586680 2023-003
    Significant Deficiency Repeat
  • 586681 2023-004
    Material Weakness Repeat
  • 586682 2023-004
    Material Weakness Repeat
  • 586683 2023-004
    Material Weakness Repeat
  • 586684 2023-005
    Significant Deficiency Repeat
  • 586685 2023-005
    Significant Deficiency Repeat
  • 586686 2023-005
    Significant Deficiency Repeat
  • 586687 2023-006
    Material Weakness Repeat
  • 586688 2023-006
    Material Weakness Repeat
  • 586689 2023-006
    Material Weakness Repeat
  • 586690 2023-007
    Significant Deficiency Repeat
  • 586691 2023-007
    Significant Deficiency Repeat
  • 586692 2023-008
    Material Weakness
  • 586693 2023-008
    Material Weakness
  • 586694 2023-008
    Material Weakness
  • 586695 2023-009
    Significant Deficiency
  • 586696 2023-009
    Significant Deficiency
  • 586697 2023-009
    Significant Deficiency
  • 586698 2023-009
    Significant Deficiency
  • 586699 2023-005
    Significant Deficiency Repeat
  • 586700 2023-005
    Significant Deficiency Repeat
  • 586701 2023-010
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.77M
84.063 Federal Pell Grant Program $2.61M
84.031 Higher Education_institutional Aid $720,353
84.149 Migrant Education_college Assistance Migrant Program $471,416
84.141 Migrant Education_high School Equivalency Program $464,776
84.042 Trio_student Support Services $298,722
47.074 Biological Sciences $159,648
84.217 Trio_mcnair Post-Baccalaureate Achievement $133,446
84.033 Federal Work-Study Program $111,988
84.007 Federal Supplemental Educational Opportunity Grants $106,506
84.215 Fund for the Improvement of Education $64,806
84.425 Education Stabilization Fund $44,646
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $43,378
84.184 Safe and Drug-Free Schools and Communities_national Programs $41,814
10.558 Child and Adult Care Food Program $37,872
93.011 National Organizations of State and Local Officials $27,151
43.001 Science $20,010
10.310 Agriculture and Food Research Initiative (afri) $18,577
47.076 Education and Human Resources $15,699
93.732 Mental and Behavioral Health Education and Training Grants $8,757
45.164 Promotion of the Humanities_public Programs $8,468
45.024 Promotion of the Arts_grants to Organizations and Individuals $5,000
45.129 Promotion of the Humanities_federal/state Partnership $2,297
84.038 Federal Perkins Loan Rogram $0