Finding 1115417 (2024-001)

Finding 2024-001 Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The School is required to report enrollment information under the Direct loan program via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). 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. 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full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).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: During our testing of student enrollment reporting, we noted the following exceptions: • For 15 of 36 selected students, the School failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe. • For 22 of 36 selected students, the School did not accurately report the student’s campus level enrollment status to the NSLDS. • For 3 of 25 selected students, there was no Program-Level Record on the NSLDS website to verify the school accurately reported the required significant data elements required by the U.S. Department of Education. • For 1 of 25 selected students, the School did not accurately report the student’s program level information to NSLDS. Cause: Insufficient administrative oversight and internal controls with respect to enrollment reporting requirements. Effect or Potential Effect: The School is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to all aspects of enrollment reporting. Questioned Costs: None. Context: We tested a sample of students and found exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: This is a repeat finding from prior the year. This was reported as finding 2023-002 in the 2023 report. Recommendation: We recommend that the School enhance its procedures and internal controls to ensure that all status changes are submitted to the NSLDS website within the required timeframe and all required data elements are reported on the NSLDS website. Views of Responsible Officials and Planned Corrective Actions: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also implement an automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. All student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems. We will complete the corrective action no later than March 31, 2025.