Finding 24154 (2022-002)

- Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-02-08
Audit: 21752
Organization: Bay Path University (MA)

AI Summary

  • Core Issue: The University failed to report student enrollment changes to the NSLDS within the required 60-day timeframe for 2 out of 40 students tested.
  • Impacted Requirements: Compliance with 34 CFR 685.309(b)(2) and 2 CFR Part 200, which mandate timely reporting of enrollment status changes.
  • Recommended Follow-Up: Provide training for staff on NSLDS reporting requirements and consider submitting additional rosters to improve compliance.

Finding Text

Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] 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. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (ED) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (NSLDS). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (NSLDS) within 60 days. During our testing, we noted 2 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or approximately 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 188 to 284 days. Identification as a Repeat Finding, if applicable See finding 2021-001 included in the summary schedule of prior year findings. Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the University?s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding.

Corrective Action Plan

Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063 and 84.268 Award year: 2022 Corrective Action Plan: The University evaluated both student records to determine the cause for the late reporting to NSLDS. The first student reported in this finding completed their degree requirements after the conclusion of the semester and the enrollment status reporting to the National Student Loan Clearinghouse. The policy of the University is to manually update NSLC however, the student was inadvertently missed in this process. The University office responsible for reporting enrollment status changes has determined this to be an isolated instance. The second student in this finding did not have their change in enrollment status updated in the early May reporting to NSLC as the student?s status did not change until two weeks later. The student?s record was rejected on the June NSLC report and not re-reported until the fall semester report. The office responsible for reporting enrollment status changes have updated their procedures to identify and review rejected student enrollment records. Rejected enrollment records will be evaluated by the reporting office and manually update NSLC with the accurate enrollment status to ensure proper updates are completed in a timely manner. Timeline for Implementation of Corrective Action Plan: Fiscal year 2023 Contact Person Stephanie King Executive Director of Student Financial Services

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $35.22M
84.063 Federal Pell Grant Program $3.71M
84.038 Federal Perkins Loan Program (beginning of Year) $1.98M
84.031 Higher Education_institutional Aid $499,098
84.007 Federal Supplemental Educational Opportunity Grants $339,883
84.033 Federal Work-Study Program $324,755
93.884 Grants for Primary Care Training and Enhancement $248,571
84.425 Education Stabilization Fund $200,000
93.732 Mental and Behavioral Health Education and Training Grants $195,243