Finding 1137447 (2024-001)

Brigham Young University - Hawaii SCHEDULE OF FINDINGS AND QUESTIONED COSTS for the year ended December 31, 2024 Section III – Federal Award Findings and Questioned Costs Finding 2024-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to the National Student Loan Data System (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program Award Years: 7/2023 – 6/2025 Criteria 34 CFR 685.309(b): (1) Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary. (2) Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition Of the population of students who had a status change and received Pell Grants and/or Direct Loans during the period January 1, 2024 through December 31, 2024, 60 students were selected for enrollment reporting testing of the campus level and program level records. Of the 60 students selected, there were exceptions noted for 42, some of which include multiple exceptions: • There were 31 instances noted in which students’ program enrollment status was reported incorrectly to the National Student Loan Data System (NSLDS) due to a systemic withdrawal of students as of 12/7/23 (26 instances in Spring 2024, four in Winter 2024, and one in Fall 2024). The campus-level status however, was reported correctly to (NSLDS) for 28 of these selections. The University’s registrar’s office was unaware of this systemic withdrawal of students until it was noted in our testing. • There were six instances noted in which the program begin date was reported incorrectly to NSLDS. One instance in Winter 2024, four in Spring 2024, and one in Fall 2024. This is a repeat of finding 2023-001. • There were seven instances noted in which the program enrollment status was reported incorrectly to NSLDS (two in Winter 2024 and five in Spring 2024), and one instance noted in which the program enrollment effective date was incorrectly reported to NSLDS (Fall 2024). • There were three instances noted in which the campus enrollment status was reported incorrectly to NSLDS (one in Winter 2024, two in Spring 2024), and three instances where the campus enrollment effective date was incorrectly reported (one in Winter 2024 and two in Spring 2024). • There was one instance noted in Fall 2024 in which the student’s status change was not reported to NSLDS within the required 60-day timeframe and there was one instance noted in Fall 2024 in which the student enrollment was not reported to NSLDS. Cause Management reviewed their process for identifying and submitting enrollment status changes to the National Student Clearinghouse (NSC), which the University utilizes to report enrollment rosters, inclusive of student status changes, on a regular basis. Management discovered that PeopleSoft, the University’s student information system, was not receiving the proper configuration updates to keep in line with current reporting standards. Additionally, the individual responsible for the enrollment reporting process was not using best practices in submitting their reports properly, nor were they properly reviewing the error reports from NSC to address the errors arising from submissions. As a result, the university experienced a high volume of enrollment statuses, particularly at the program level, that were reported incorrectly to NSLDS. The six instances of program begin dates being incorrectly reported relate to a system error within PeopleSoft in which the system inappropriately codes certain students’ enrollment with the wrong program begin date. Specifically, when a student returns from a leave of absence, PeopleSoft creates a new version of the program. The new version of the program resets the program begin date to when the student returned instead of when the student originally began the program. Effect A student’s campus enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for payment of interest subsidies, all of which are impacted by inaccurate and untimely reporting. As we only noted four instances where campus enrollment status and three instances where the campus enrollment effective dates were incorrectly reported, we note minimal impact to the federal government’s assistance programs. Questioned Costs None Recommendation We recommend that the University perform a detailed review of its enrollment reporting process and identify where errors are occurring. We recommend the University provide adequate training to the individuals responsible for updating students’ electronic files and obtain outside assistance in the form of consulting to ensure status changes are reported accurately to NSLDS. Management’s Views and Corrective Action Plan Management’s response is reported in management’s view and corrective action plan included at the end of this report.