Finding Text
2022-001 Enrollment Reporting Student Financial Assistance Cluster: U.S. Department of Education: Federal Direct Student Loan Program (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Federal Grant Numbers: P063P210268 (07/01/2021-06/30/2022), P268K220268 (07/01/2021-06/30/2022) Statistically Valid Sample: No, and it was not intended to be Prior Year Finding: N/A Finding Type: Significant Deficiency and Noncompliance Criteria Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). 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 verify 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. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that the Department of Education (ED) considers high risk: ? OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: ? OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. There were 40 students selected for testwork, and the following exception was identified: ? For 1 of the 40 students selected for testwork, the University did not report the student?s status change as graduated to NSLDS on the Campus-Level Record. Cause There was an error when the University attempted to update the student?s status in the Campus-Level and Program-Level records in NSLDS. When taking action on the error, only the student?s Program-Level record was updated with the graduated enrollment status. The student?s status in the Campus-Level record was not updated to graduated. Effect Student status changes not reported in an accurate or timely manner will cause the student to not enter into repayment status on a timely basis. Questioned Costs No questioned costs were noted as a result of the audit procedures performed. Recommendation We recommend the University review its current policies and procedures to ensure that all status changes are reported to NSLDS correctly at both the Campus-Level and Program-Level, within the required timeframe. Views of Responsible Officials During fiscal year 2022, a student was found to have been reported as withdrawn, when they, in fact, graduated. The University determined that when it was notified by the Clearinghouse) that the student?s graduation status did not generate, the University made the correction to the Program-Level record status, but failed to update the Campus-Level record status. Therefore, when the ?First of Term? file for the Fall term was transmitted, the student was not included, and was incorrectly reported as withdrawn. As part of a corrective action, the University immediately corrected the Campus-Level Record status for the student to graduated and confirmed that the updated status was reported to NSLDS. Effective immediately, the University?s business practice will include using a two-person team to review the Clearinghouse error resolution reports to ensure that all corrections are made on both the Program-Level and the Campus-Level records to ensure that they are properly reflected in NSLDS.