Finding Text
2024-006 Enrollment Reporting
Compliance Requirement Special Tests and Provisions
Finding Type Significant Deficiency in Internal Control and Noncompliance
Federal Agency US Department of Education
ALN 84.007, 84.033. 84.063 and 84.268
Federal Program Student Financial Aid Cluster
Criteria
As established by OMB No. 1845-0035, Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Additionally, for Direct Loans, as outlined in the 34 CFR § 685.309(b)(2)(i), schools participating in the Direct Loan Program are required to notify the Secretary within 30 days after discovering that a student who received a Title IV loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, unless the school expects to submit its next updated enrollment report within the next 60 days. Furthermore, The FSA Handbook 2023-2024, Volume 5, Chapter 2, Grant Overpayments Section, which indicates that if the school notifies the student about a Title IV overpayment determination and the student takes no action within 45 days, the school must promptly report the student to NSLDS and refer them to the Default Resolution Group.
Condition
From a sample of twenty-six students selected to test reporting the students' enrollment status, we identified three instances where the University failed to report changes to NSLDS during the 2023–2024 academic year. These involved students who officially or unofficially withdrew from the program.
Cause
Lack of proper execution of required follow-up activities, procedures, and processes, to notify the US Department of Education (ED) via the NSLDS of the withdrawal status of students after their withdrawal determination.
Effect
Effects or possible effects of the condition include risk that student loan services may not initiate proper repayment schedules or deferments, and Improper Disbursements or overaward to ineligible students in current or future periods (academic sessions). Additionally, this results in noncompliance with Federal Regulations.
Questioned Costs
None
Recommendation
We recommend that the University should strengthen its internal procedures and/or implement additional controls to identify unofficial withdrawals and ensure timely updates to the NSLDS. This includes improved coordination and communication between the Financial Aid Office and the Registrar’s Office to proactively monitor students flagged with a withdrawal with grade F (WF) before and at the end of the academic session, as well as ensuring consistency and reconciliation between the reports and systems used to identify withdrawals.
Views of responsible official
Refer to Corrective Action Plan (Unaudited)