Finding 10954 (2023-001)

2023-001 – Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). 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 that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition Through our testing of 35 enrollment reporting selections across five schools, we noted the following at one school: • For 4 out of 10 selections, we noted that the effective date of the change per the NSLDS at the program level did not agree to the effective date of the actual status change per the student file. In each of these instances the student status change was appropriately reported at the campus level. • For 6 out of 10 selections, we noted graduate students were reported to NSLDS with a withdrawn status (‘W’) rather than a graduation status (‘G’). Cause • The cause of the finding in the first instance was incorrect reporting logic that was defaulting to the first day of the term for this field, rather than the actual date of a student’s in-term time status change. • The cause of the finding in the second instance was that while the school appropriately reported the initial separation event as ‘W’, the reporting logic failed to capture the degree-awarding or graduation ‘G’ event correctly for November and March graduates only. Effect The effective administration of Title IV loans could be impacted when changes in students’ status are not reported accurately. The accuracy of enrollment information is important as the student’s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments as well as the Government’s payment of interest subsidies. Due to the student loan forbearance provided by the COVID-19 Emergency Relief, none of the selected students were impacted by the first condition above. . In regard to the second instance, there was no impact on the student’s loan repayment or eligibility as Harvard University appropriately reported the initial separation event. Questioned Costs None noted. Recommendation We recommend management implement controls to identify inconsistencies in enrollment reporting information and to ensure error reports are resolved timely. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.