FAC Explorer

Finding 1127935 (2024-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 352110
Organization: South Carolina State University (SC)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University failed to report enrollment status changes to the NSLDS on time for 15 out of 40 students, indicating a lack of compliance with federal requirements.
  • Impacted Requirements: Timely and accurate enrollment reporting is crucial for federal student aid programs; failure to comply can affect loan repayment statuses for borrowers.
  • Recommended Follow-Up: Enhance internal controls and procedures for enrollment reporting, including hiring an internal auditor and improving monitoring systems to ensure compliance.

Finding Text

Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting – Status Change – Campus Level Information on Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.007, 84.033 84.063, 84.268) Criteria or Specific Requirement – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. 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. Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The University did not submit timely notification to the NSLDS website for certain students selected for testing. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University is not in compliance with campus level enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs – None. Context – For 15 of 40 students selected for testing, the University did not submit a timely notification to the NSLDS website. Indication of Repeat Finding - This is a repeat of prior year finding 2023-002. Recommendation – We recommend that the University enhance its procedures and internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials – The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations.

Categories

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 551465 2024-006
    Significant Deficiency
  • 551466 2024-006
    Significant Deficiency
  • 551467 2024-006
    Significant Deficiency
  • 551468 2024-006
    Significant Deficiency
  • 551469 2024-006
    Significant Deficiency
  • 551470 2024-006
    Significant Deficiency
  • 551471 2024-006
    Significant Deficiency
  • 551472 2024-006
    Significant Deficiency
  • 551473 2024-006
    Significant Deficiency
  • 551474 2024-006
    Significant Deficiency
  • 551475 2024-006
    Significant Deficiency
  • 551476 2024-006
    Significant Deficiency
  • 551477 2024-006
    Significant Deficiency
  • 551478 2024-006
    Significant Deficiency
  • 551479 2024-006
    Significant Deficiency
  • 551480 2024-006
    Significant Deficiency
  • 551481 2024-006
    Significant Deficiency
  • 551482 2024-006
    Significant Deficiency
  • 551483 2024-006
    Significant Deficiency
  • 551484 2024-006
    Significant Deficiency
  • 551485 2024-006
    Significant Deficiency
  • 551486 2024-006
    Significant Deficiency
  • 551487 2024-006
    Significant Deficiency
  • 551488 2024-006
    Significant Deficiency
  • 551489 2024-006
    Significant Deficiency
  • 551490 2024-006
    Significant Deficiency
  • 551491 2024-006
    Significant Deficiency
  • 551492 2024-006
    Significant Deficiency
  • 551493 2024-001
    Significant Deficiency Repeat
  • 551494 2024-003
    Significant Deficiency
  • 551495 2024-001
    Significant Deficiency Repeat
  • 551496 2024-003
    Significant Deficiency
  • 551497 2024-002
    Significant Deficiency Repeat
  • 551498 2024-001
    Significant Deficiency Repeat
  • 551499 2024-003
    Significant Deficiency
  • 551500 2024-001
    Significant Deficiency Repeat
  • 551501 2024-003
    Significant Deficiency
  • 551502 2024-004
    Significant Deficiency
  • 551503 2024-005
    Significant Deficiency
  • 551504 2024-003
    Significant Deficiency
  • 1127907 2024-006
    Significant Deficiency
  • 1127908 2024-006
    Significant Deficiency
  • 1127909 2024-006
    Significant Deficiency
  • 1127910 2024-006
    Significant Deficiency
  • 1127911 2024-006
    Significant Deficiency
  • 1127912 2024-006
    Significant Deficiency
  • 1127913 2024-006
    Significant Deficiency
  • 1127914 2024-006
    Significant Deficiency
  • 1127915 2024-006
    Significant Deficiency
  • 1127916 2024-006
    Significant Deficiency
  • 1127917 2024-006
    Significant Deficiency
  • 1127918 2024-006
    Significant Deficiency
  • 1127919 2024-006
    Significant Deficiency
  • 1127920 2024-006
    Significant Deficiency
  • 1127921 2024-006
    Significant Deficiency
  • 1127922 2024-006
    Significant Deficiency
  • 1127923 2024-006
    Significant Deficiency
  • 1127924 2024-006
    Significant Deficiency
  • 1127925 2024-006
    Significant Deficiency
  • 1127926 2024-006
    Significant Deficiency
  • 1127927 2024-006
    Significant Deficiency
  • 1127928 2024-006
    Significant Deficiency
  • 1127929 2024-006
    Significant Deficiency
  • 1127930 2024-006
    Significant Deficiency
  • 1127931 2024-006
    Significant Deficiency
  • 1127932 2024-006
    Significant Deficiency
  • 1127933 2024-006
    Significant Deficiency
  • 1127934 2024-006
    Significant Deficiency
  • 1127936 2024-003
    Significant Deficiency
  • 1127937 2024-001
    Significant Deficiency Repeat
  • 1127938 2024-003
    Significant Deficiency
  • 1127939 2024-002
    Significant Deficiency Repeat
  • 1127940 2024-001
    Significant Deficiency Repeat
  • 1127941 2024-003
    Significant Deficiency
  • 1127942 2024-001
    Significant Deficiency Repeat
  • 1127943 2024-003
    Significant Deficiency
  • 1127944 2024-004
    Significant Deficiency
  • 1127945 2024-005
    Significant Deficiency
  • 1127946 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $24.58M
84.063 Federal Pell Grant Program $12.15M
84.031 Higher Education Institutional Aid $5.26M
10.205 Payments to 1890 Land-Grant Colleges and Tuskegee University $3.22M
10.512 Extension Services at 1890 Colleges and Tuskegee University, West Virginia State College, and Central State University $2.40M
10.912 Environmental Quality Incentives Program $1.25M
84.007 Federal Supplemental Educational Opportunity Grants $939,527
10.524 Scholarships for Students at 1890 Institutions $848,900
93.516 Public Health Training Centers Program $823,482
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $758,070
84.263 Innovative Rehabilitation Training $572,347
84.382 Strengthening Minority-Serving Institutions $571,081
59.059 Congressional Grants $547,273
81.137 Minority Economic Impact $501,018
10.216 1890 Institution Capacity Building Grants $430,370
10.237 From Learning to Leading: Cultivating the Next Generation of Diverse Food and Agriculture Professionals $423,956
84.033 Federal Work-Study Program $388,582
84.425 Education Stabilization Fund $371,663
81.RD Department of Energy $348,846
93.397 Cancer Centers Support Grants $331,898
84.042 Trio Student Support Services $292,913
20.237 Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements $248,962
84.129 Rehabilitation Long-Term Training $246,583
47.076 Stem Education (formerly Education and Human Resources) $238,428
59.037 Small Business Development Centers $232,426
81.104 Environmental Remediation and Waste Processing and Disposal $223,653
10.937 Partnerships for Climate-Smart Commodities $213,033
10.514 Expanded Food and Nutrition Education Program $185,091
84.264 Rehabilitation Training Technical Assistance Centers $157,940
84.120 Minority Science and Engineering Improvement $146,689
12.U01 U.s. Department of Defense $131,093
47.049 Mathematical and Physical Sciences $88,674
10.170 Specialty Crop Block Grant Program - Farm Bill $76,382
10.311 Beginning Farmer and Rancher Development Program $61,055
93.959 Block Grants for Prevention and Treatment of Substance Abuse $56,532
81.113 Defense Nuclear Nonproliferation Research $54,538
20.701 University Transportation Centers Program $52,657
84.027 Special Education Grants to States $49,071
81.049 Office of Science Financial Assistance Program $47,785
12.800 Air Force Defense Research Sciences Program $46,236
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $43,339
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $42,480
10.025 Plant and Animal Disease, Pest Control, and Animal Care $42,290
10.523 Centers of Excellence at 1890 Institutions $40,556
10.902 Soil and Water Conservation $39,720
47.083 Integrative Activities $37,847
84.116 Fund for the Improvement of Postsecondary Education $36,109
12.330 Science, Technology, Engineering & Mathematics (stem) Education, Outreach and Workforce Program $34,258
10.960 Technical Agricultural Assistance $32,674
12.598 Centers for Academic Excellence $30,554
93.350 National Center for Advancing Translational Sciences $17,897
10.515 Renewable Resources Extension Act $16,405
10.500 Cooperative Extension Service $16,360
11.431 Climate and Atmospheric Research $12,211
10.328 Food Safety Outreach Program $10,474
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $7,073
15.904 Historic Preservation Fund Grants-in-Aid $3,637
45.129 Promotion of the Humanities Federal/state Partnership $1,750
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $80
84.038 Federal Perkins Loan Program_federal Capital Contributions $0