Finding Text
Finding 2024-001
Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Direct Student Loans (Assistance Listing #84.268) Federal Award Number: P268K241866
Federal Pell Grant Program (Assistance Listing #84.063) Federal Award Number: P063P231866
Federal Award Year: 2023-2024
Criteria:
Under the Federal Pell Grant Program and U.S. Department of Education (“ED”) loan programs, institutions are required to report student enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). 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 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 website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains as the most recently certified enrollment information. 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. Required program-level data includes, but is not limited to:
• Program enrollment status;
• Program enrollment effective date;
• Program begin date;
• Published program length and measurement; and,
• Classification of Instructional Program (“CIP”) code.
When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change).
Context and Condition:
From a selection of forty (40) students tested, we identified the following instance of noncompliance:
1) For two (2) students, the change in status was not submitted timely (within 60 days) to the NSLDS per the student records and internal documentation provided by the University.
Cause:
For the two (2) students, management entered the incorrect effective date of the respective student’s withdrawal status. The error was identified and corrected by management, however the updated effective date was not certified timely (within 60 days) to the NSLDS.
Effect:
The enrollment status for two (2) students were not reported timely to the NSLDS.
Questioned Costs:
None identified.
Identified as a Repeat Finding:
Yes.
Recommendation:
The University should implement procedures to ensure that withdrawal dates are reported timely to the NSLDS.
Views of Responsible Officials:
Molloy University understands the finding and has devised a process to ensure that the correct withdrawal date is recorded National Student Loan Data System (NSLDS) with the 60-day window from the date of determination. In the finding, the withdrawals were reported within the window, but the effective dates reported were incorrect. We identified the issue and made the corrections, but the corrections were made outside the 60-day window. To address this, we will utilize our current practice of relying on error reports to address such errors, but we will run these reports at an increased frequency (bi-weekly) and have an additional staff member review the information. We will keep a file for each student withdrawal to show that our dates align in our system, the National Student Clearinghouse, and NSLDS within the required timeframe.