Finding Text
2025-003 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Department of Education Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P242403, P268K252403 Award Year: 2024-25, 2023-24, 2022-23, 2021-22 Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – We selected a sample of 23 students out of a population of 251 who had received Federal aid and were reported to NSLDS during the fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University’s records. We noted exceptions with 9 out of the 23 students tested which included the following: • 4 selections were not reported to NSLDS within the required timeframe. • 2 selections reported a program level enrollment status to NSLDS that did not properly reflect the student’s enrollment status. Additionally, for these 2 selections we were unable to verify that the campus level status was reported timely based on the support provided. • 2 selections reported both a campus level and program level enrollment status to NSLDS that did not properly reflect the student’s enrollment status. • 1 selection reported a program level beginning date and enrollment status effective date for both campus and program level to NSLDS that did not match the students’ records. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and oversight of the process. This resulted in incomplete and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding – Yes, 2024-003 Recommendation – We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Views of responsible officials and planned corrective actions – Heritage University agrees with the recommendation and is strengthening its enrollment reporting and monitoring processes. The University is focused on building capacity within the Financial Aid department, clearly assigning responsibility for enrollment reporting activities, and establishing specific timelines and checkpoints to ensure required status changes are identified, reviewed, and submitted within required timeframes.