Finding Text
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
ALN Number: Student Financial Aid Cluster
Award Period: June 01, 2023 through May 31, 2024
Type of Finding:
* Significant Deficiency in Internal Control over Compliance
* Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. In addition, we noted for 4 out of the 40 students tested, the enrollment effective date per NSLDS did not match the enrollment effective date per the University’s records.
Questioned Costs: None
Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting.
Cause: The University did not have a process in place to ensure the effective dates reported matched the University’s records as well as that these changes were reported timely.
Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. In addition, the University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely.
Repeat finding: No
Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University.
Views of responsible officials: There is no disagreement with the audit finding.