Finding 1127616 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 352071
Organization: Mercy College (NY)

AI Summary

  • Core Issue: The University failed to report graduation effective dates for 20 students to NSLDS within the required 60-day timeframe due to a system error in Banner.
  • Impacted Requirements: Timely and accurate reporting of enrollment information is crucial for compliance with federal regulations under the Pell Grant and Direct Loan programs.
  • Recommended Follow-Up: Strengthen policies and procedures to ensure timely submissions, and implement backup reporting processes to prevent future delays.

Finding Text

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. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845 0002) mailboxes sent by the Department of Education (“ED”) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Context: The University distributes Direct Loans and Pell grants to students and is thus required to report the Campus-Level and Program-Level enrollment information of these students to NSLDS both timely and accurately. Condition: We identified the following instances of noncompliance from a selection of forty (40) graduated students selected for enrollment reporting testing: • Twenty (20) students whose graduation effective dates were not reported timely (within 60 days) to the NSLDS. Cause: The University uses Banner to create a file of graduates that is reported to the National Student Clearinghouse. A system error in Banner delayed creation of the file and the timely reporting of the graduates. Effect: While the data that was transmitted to the NSLDS was accurate, the University did not timely report graduation effective dates for twenty (20) students. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: The University should strengthen policies and procedures to ensure that enrollment effective dates are submitted timely to the NSLDS. Views of Responsible Officials: There is a Banner process which creates the file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process last spring rendering the process unable to generate a file. The error was not resolved until early May, which is when the submission for these students was completed. This was a one-time specific system failure occurrence which has been resolved, and the process has been working correctly since May 2024. The Offices of the Registrar and Student Financial Services are working in conjunction with the University compliance team and Office of Institutional Research to enhance review and checks/balances of reporting deadlines to ensure that files are submitted within the required deadlines. Further, the Office of the Registrar will work with internal IT staff to research and implement backup reporting procedures for creating enrollment and graduation files in the event of another system issue.

Categories

Student Financial Aid Reporting Eligibility Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 551172 2024-001
    Significant Deficiency
  • 551173 2024-001
    Significant Deficiency
  • 551174 2024-001
    Significant Deficiency
  • 551175 2024-001
    Significant Deficiency
  • 551176 2024-001
    Significant Deficiency
  • 1127614 2024-001
    Significant Deficiency
  • 1127615 2024-001
    Significant Deficiency
  • 1127617 2024-001
    Significant Deficiency
  • 1127618 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $19.37M
84.268 Federal Direct Student Loans $10.26M
84.007 Federal Supplemental Educational Opportunity Grants $1.11M
11.028 Connecting Minority Communities Pilot Program $1.11M
84.033 Federal Work-Study Program $900,649
84.184 School Safely National Activities $703,885
93.925 Scholarships for Health Professions Students From Disadvantaged Backgrounds $677,591
84.425 Education Stabilization Fund $557,325
93.732 Mental and Behavioral Health Education and Training Grants $479,006
84.042 Trio Student Support Services $363,335
93.264 Nurse Faculty Loan Program (nflp) $334,428
84.217 Trio McNair Post-Baccalaureate Achievement $278,172
84.377 School Improvement Grants $252,190
84.031 Higher Education Institutional Aid $208,252
12.905 Cybersecurity Core Curriculum $171,386
84.120 Minority Science and Engineering Improvement $93,878
47.074 Biological Sciences $91,236
97.062 Scientific Leadership Awards $40,603
47.076 Stem Education (formerly Education and Human Resources) $18,011
93.137 Community Programs to Improve Minority Health $499
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $-15,352