Finding Text
2024-002: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.268, Federal Direct Student Loans, and #84.063, Federal Pell Grant Program
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information including that previously provided by the student and the institution.”
Per 34 CFR 685.309(b), “Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary.”
Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.”
Per 2.4 of the NSLDS Enrollment Reporting Guide, “NSLDS tracks how many students, included on a school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance.”
Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.”
Condition/context: Of the seven students selected for testing of accurate enrollment reporting, we noted the following errors:
• Two instances in which the students were not reported as withdrawn at the Program-Level;
• One instance in which the student’s published program length was incorrect;
• One instance in which the student was reported as withdrawn with the incorrect effective date; and
• Three instances in which the student was not reported within 60 days of the date of determination.
Cause: The Student Financial Aid and Registrar Offices do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status.
Questioned costs: None.
Identification as a repeat finding: Yes.
Recommendation: The Student Financial Aid and Registrar Offices should implement controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.