Finding Text
Finding No.: 2024-001 – Enrollment Reporting
Federal Agency: U.S. Department of Education
Pass-through Agency: Direct
Program Name: Student Financial Assistance Cluster – Federal Direct Loan
Program, Federal Pell Grant Program
CFDA Numbers: 84.268, 84.063
Federal Award Year: July 1, 2023 – June 30, 2024
Criteria
Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (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 reported by institutions.
The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC).
Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award.
Condition Found
The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified two (2) students whose changes in enrollment status were not timely transmitted to NSLDS, as follows:
• For one (1) student, the University was notified of the student’s enrollment status change from full-time to “Withdrew” in May 2024. Accordingly, the student’s’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was sixty-seven (67) days after the required submission date.
• For one (1) student, the University placed the student on academic suspension on June 3, 2024. Accordingly, the students’ status change should have been transmitted within 60 days of that date. However, submission was not timely as the final submission of change of status was fifty (50) days after the required submission date.
Cause
In both of these instances, the University’s summer enrollment reporting process of only reporting applicable changes for students enrolled in summer courses failed to identify these changes as neither student was enrolled in a summer course. Possible Asserted Effect
Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Questioned Costs
No questioned costs were identified.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
A portion of prior year finding 2023-001 related to issues affecting timeliness of enrollment reporting resulting from the University’s internal control processes not operating consistently to ensure that all enrollment changes, including transfers effective at the end of the semester, be submitted timely to NSLDS.
Recommendation
We recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner.
Views of Responsible Officials
The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies.
The delay in reporting the enrollment status changes for two students was due to the University's summer enrollment reporting process only reporting changes for students enrolled in summer courses. This process failed to identify status changes reported after the end of the spring semester when the student was not enrolled in the summer. As a result, the status change was not picked up for reporting until late summer. To address and prevent such issues in the future, the University has implemented enhanced controls to capture status changes outside of the term being reported. These measures, along with clearly defined procedures for managing enrollment reporting ensures the timely submission of status changes.
Additionally, the University commits to conducting regular reviews and updates of its reporting processes to ensure compliance with federal requirements and to avoid potential delays in the future.