Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program
Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2020-003, 2021-003, 2022-002
Criteria - Schools are required to report enrollment information under the Direct Loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV Student Financial Assistance 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. There are two categories of enrollment information, campus level and program level, both of which need to be reported accurately.
Condition - Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS.
Questioned Costs - None
Context - During our testing of a sample of seven students, we noted the following exceptions:
1) For five students, student enrollment was not certified within the required 60 day time period.
2) For two students, the students were reported inaccurately as withdrawn and should have been reported as graduated.
Cause and Effect - The School has neither a process or controls in place to ensure that campus level data and program level student enrollment information is reported to NSLDS in a timely and accurate manner.
Untimely and inaccurate reporting of student enrollment data to NSLDS results in noncompliance with federal regulations and untimely or inaccurate data listed within NSLDS. Student information within NSLDS is used to determine award packaging for students attending multiple institutions and repayment periods on direct student loans; inaccurate or stale data within NSLDS could lead to improper award packaging and repayment period determinations.
Recommendation - We recommend the School implement a control to ensure all campus level and program level student enrollment information is reported to NSLDS timely and accurately in accordance with the federally required timelines.
Views of Responsible Officials and Corrective Action Plan - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting.