Finding Text
Finding number: 2023-04
Federal agency: U.S. Department of Education
Programs: Student Financial Assistance Cluster
Assistance Listing #: 84.063, 84.268
Award year: 2023
Criteria
According to 34 CFR 685.309(b)(2):
Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that –
(i) 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; or
(ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his
or her permanent address.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 2 out of 27 students were reported late to the NSLDS by 98 days. During our testing, 1 out of 27 students reported an incorrect effective date, and 4 out of 27 students had an incorrect status reported to the NSLDS.
Cause
Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly.
Effect
Franklin Cummings Tech did not report the students’ correct effective dates and status to NSLDS or were not
reported within the required timeframe, which may impact the students’ loan grace periods.
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 27 students selected for testing, 4 students, or 14.8% of our sample, did not report the correct effective dates and status to NSLDS or were not reported within the required timeframe.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations.
View of Responsible Officials
Franklin Cummings Tech agrees with the finding.