Finding Text
Finding 2024-002 - Significant Deficiency: Special Tests and Provisions -
Compliance and Control Finding
ALN 84.063 - Federal Pell Grant Program and 84.268 - Federal Direct Student
Loan Program - Student Financial Aid Cluster
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Per 34 CFR 682.610 (and further clarified in the November 2022 National Student Loan Data System (NSLDS) Enrollment Reporting Guide), a University is required to certify changes in enrollment data for students within 60 days of the change. Universities are responsible for accurately reporting
certain key information, such as the OPEID number, enrollment effective date, enrollment status, graduation status and certification date.
Condition: The University has established several processes and procedures to ensure that enrollment reporting occurs on a timely basis. These processes and procedures rely on an internal reporting mechanism that assesses a multitude of factors, including the end date on programs with a future term. The end date on programs is a key data point to ensure that enrollment reporting is occurring in a timely manner.
Cause: The University utilizes several pseudo courses to ensure that students who are graduating from a 5-week, 3 term program are properly assessed certain published fees.
These pseudo courses are structured as a future registration in the system, and resulted in inaccurate data on the reporting mechanism that the University relies on for timely and accurate enrollment reporting.
Effect: The University’s controls may not prevent potential errors related to timely certification of enrollment reporting.
Questioned Costs: Not applicable.
Context: Our audit sample of 40 students, we noted 1 student that was updated in NSLDS outside of the 60-day requirement period.
Identification As A Repeat Finding: This is not a repeat finding.
Recommendation: The University should revise the process and internal controls surrounding enrollment reporting to ensure that all enrollment reporting status changes are certified to NSC and thereby NSLDS within the 60-day requirement period.
Views Of Responsible Officials: The University acknowledges that the enrollment reporting controls need to be enhanced to ensure timely submission to NSLDS.