Finding 25011 (2022-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-02-09
Audit: 26146
Organization: Sweet Briar Institute (VA)
Auditor: Bdo USA LLP

AI Summary

  • Core Issue: The Institute failed to report updated enrollment statuses and CIP codes for students, leading to non-compliance with federal requirements.
  • Impacted Requirements: Accurate reporting of enrollment status and program information is critical for Pell and Direct Loan programs, as outlined in NSLDS guidelines.
  • Recommended Follow-Up: Enhance internal controls and procedures for enrollment reporting to prevent future compliance issues, especially with updated CIP codes.

Finding Text

Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.063 and #84.268) Criteria or Specific Requirement ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (?FFEL?) loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment Compliance Supplement 2022 5-3-51 April 2022 Student Financial Assistance Cluster reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 which the financial aid administrator can access for the auditor. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (?CIP?) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (?NCES?). They were most recently updated in 2020 and are usually updated every ten years. Condition ? Campus Level: For 4 students that had enrollment status changes, the Institute did not subsequently certify updated enrollment status to NSLDS. Program Level: For 4 students, the Institute did not submit updated CIP Codes to NSLDS once the students changed his/her field of study. Cause - Administrative oversight in internal controls over enrollment reporting requirements. Effect or Potential Effect - The Institute was not in compliance with the enrollment reporting requirements. Questioned Costs ? None. Context ? The context at the campus level and program level is as follows: Campus Level: 4 of 12 students selected for student status change testing. Program Level: 4 of 25 students selected for program level testing. Indication of Repeat Finding - This is a partial repeat of prior year finding 2021-002. Recommendation ? We recommend that the Institute enhances its procedures and its internal controls over enrollment reporting requirements. Views of Responsible Officials ? The Institute agrees with this finding. The finding is related to required enrollment information being reported to National Student Loan Data System which can include a variety of part time statuses as well as changes in field of study. All 3 of the students indicated as not being reported were from changes in field of study. The data to be reported includes CIP codes provided by the U.S. Department of Education. The CIP codes were updated in 2020, and the college did not update its registration system. With the old Classification of Instructional Programs (?CIP?) codes used in the enrollment change reporting, the changes were effectively shown as ?not reported?. The Registrar?s office is updating all CIP codes in the Banner database to correct this going forward. Since it is more than halfway through fiscal 2022-23, it may possibly show as an issue next year prior to February 1, 2023.

Corrective Action Plan

Individuals Responsible for Corrective Action Plan Wanda Spradley, Director Financial Aid and Jennifer Sauer, AVP and Controller Finding 2022-001 Corrective Action Plan: The finding is related to required enrollment information being reported to National Student Loan Data System which can include a variety of part time statuses as well as changes in field of study. All 3 of the students indicated as not being reported were from changes in field of study. The data to be reported includes Classification of Instructional Programs (?CIP?) codes provided by the U.S. Department of Education. The CIP codes were updated in 2020, and the college did not update its registration system. With the old codes used in the enrollment change reporting, the changes were effectively shown as ?not reported?. The Registrar?s office is updating all CIP codes in the Banner database to correct this going forward. Since it is more than halfway through fiscal 2022-23, it may possibly show as an issue next year prior to February 1, 2023. Anticipated Completion Date: February 28, 2023

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 25012 2022-001
    Significant Deficiency Repeat
  • 601453 2022-001
    Significant Deficiency Repeat
  • 601454 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.15M
84.063 Federal Pell Grant Program $779,282
84.425 Education Stabilization Fund $100,000
84.007 Federal Supplemental Educational Opportunity Grants $41,802
84.033 Federal Work-Study Program $40,089
84.038 Federal Perkins Loan Program $0