Finding 1100758 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-24
Audit: 343512
Organization: Iona College (NY)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University inaccurately reported significant data elements under the Program-Level record on the NSLDS website.
  • Impacted Requirements: Institutions must report accurate enrollment information every 60 days, including critical data like enrollment status and program details.
  • Recommended Follow-Up: Enhance internal controls and procedures for enrollment reporting, including a monthly review process to ensure data accuracy.

Finding Text

Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting Information on Federal Program(s) – Federal Direct Student Loan Program (Federal Assistance Listing #84.268) Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date. Condition – The University did not accurately report a student’s significant data elements under the Program-Level record on the NSLDS website. Cause – Administrative oversight in internal controls over enrollment reporting requirements. Effect or Potential Effect – The University was not in compliance with the enrollment reporting requirements. Questioned Costs – None. Context – 1 of 25 students selected for testing. Indication of Repeat Finding – No similar finding identified during the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over enrollment reporting requirements. Views of Responsible Officials – Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. To address this issue, the University has implemented a corrective action plan that includes updating our reporting frequency and enhancing our data review processes: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. Previous institutional practice did not include reporting program level data for these terms given that said terms do not involve federal financial aid. This change ensures that all Program-Level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer will review a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer will summarize the findings and share them with the Associate Registrar and Registrar for a secondary review. Any necessary edits will be made, followed by a review of an additional 25 students to ensure accuracy. We believe these corrective action steps are critical to ensuring accurate reporting and preventing this issue in the future.

Categories

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 524316 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $29.82M
84.063 Federal Pell Grant Program $4.95M
84.033 Federal Work-Study Program $502,561
93.732 Mental and Behavioral Health Education and Training Grants $484,511
84.007 Federal Supplemental Educational Opportunity Grants $432,786
84.217 Trio McNair Post-Baccalaureate Achievement $344,066
84.042 Trio Student Support Services $266,416
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $251,592
47.076 Stem Education (formerly Education and Human Resources) $112,415
59.077 Community Navigator Pilot Program $86,320
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $84,869
47.074 Biological Sciences $30,222
47.049 Mathematical and Physical Sciences $12,343