Finding 11741 (2023-001)

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Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-05
Audit: 15539
Organization: Marion Military Institute (AL)
Auditor: Forvis LLP

AI Summary

  • Core Issue: The Institute failed to notify NSLDS on time about changes in student enrollment status.
  • Impacted Requirements: Compliance with 34 CFR 685.309(b) regarding timely updates to student enrollment information.
  • Recommended Follow-Up: Management should create procedures to ensure timely reporting of student status changes to NSLDS.

Finding Text

Student Financial Assistance Cluster 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loans U.S. Department of Education Award Year 2022/2023 Criteria or Specific Requirement – Special Tests and Provisions - Enrollment Reporting 34 CFR 685.309(b) states that 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 in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. 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 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. Condition – The Institute did not submit timely notification to the National Student Loan Data System (NSLDS) of student status changes. Questioned Costs – None noted Context – Out of a population of 39 student enrollment status changes requiring notification, a sample of four student status changes was selected for testing. Out of the four selected for testing, two students that had status changes were not communicated to NSLDS on a timely basis. Both students that were not reported timely were graduates in May 2023. The sampling methodology was not intended to be a statistically valid sample. Effect – The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause – The Institute uses an Enrollment Reporting Servicer (Servicer) to transmit student enrollment status changes to NSLDS. The enrollment reporting file was submitted timely by the Institute to the Servicer, however, there was a delay in the submission to NSLDS from the Servicer. Ultimately the Institute has primary responsibility for timely submission of enrollment status changes to NSLDS. Recommendation – We recommend that management review this area and establish procedures to ensure student status changes are reporting timely to NSLDS. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.

Corrective Action Plan

Personnel Responsible for Corrective Action Plan: Eva Painter – Director of Institutional Research Anticipated Completion Date: February 15, 2024 Corrective Action Plan Context - As is noted in the original finding, the Institution submitted all enrollment and degree verify files to servicer (National Student Clearinghouse) according to the transmission schedule. After reviewing the timeline and files noted in the finding, it appears that the subsequent enrollment file was sent to National Student Clearinghouse on 5/16/23, which was consequently, prior to the Registrar completing process to roll students who graduated to a “G” status. Therefore, only some of our graduates were noted as “G” status in the May Enrollment Transmission. These students that were included were reported to NSLDS with a “G” status within the prescribed time period. All graduates were included in the Degree Verify transmission later in May; however, our institution does not participate in the Clearinghouse service to automatically roll degree verify transmissions to G status. Furthermore, the following scheduled enrollment transmission in July also included all of the Graduated students as a G status, but it was not received by NSLDS within the 60-day window. It is clear that the transmission schedule needs to be edited to avoid future issues. Additionally, this finding has also shed light on the need for a clear policy on the window in which we will allow students to reverse transfer back credit, should they want to be considered graduated in the same term they were last enrolled. The director of institutional research therefore recommends two action plan items and a set of best practices to follow on a continual basis. Corrective Action Items: 1. Review and edit the Clearinghouse Transmission Schedule The submission calendar will be reviewed by both the director of institutional research and the registrar to ensure the scheduled enrollment transmissions following graduation are scheduled so that there is enough time to roll all students to G status, but also that it will be received by NSLDS within 60 days. It will be recommended that all enrollment transmissions following a scheduled graduation be transmitted by the 30th of the month graduation took place and within 14 to 16 days. For example, a transmission will be submitted by the 30th of May following a May 11th graduation. 2. Develop and Codify Reverse Transfer Policy Best Practices The Registrar and Director of Institutional Research will develop a Reverse Transfer Policy and submit to Chief Academic Officer for approval. The policy will recommend that students who wish to receive a graduation award for a graduation date that falls within their last semester attended must submit any necessary reverse transfer credit within 14 business days (excluding holidays) “of the concurred graduation date of that semester. Should the student submit reverse transfer credit after that window, the student’s graduation date will reflect that of the following concurred graduation date. Ongoing Best Practice Protocols to be immediately implemented: 1. The Director of Institutional Research will confer with Registrar to ensure all graduates have been rolled over to g status prior to sending the enrollment transmission to Clearinghouse. 2. Upon receiving any reverse transfer credit, the Registrar will notify the Director of Institutional Research, so that the student can be manually changed to “G” status in the Clearinghouse System.

Categories

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

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $931,941
84.268 Federal Direct Student Loans $663,204
84.033 Federal Work-Study Program $22,965
84.007 Federal Supplemental Educational Opportunity Grants $15,370