Finding Text
Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Student Loans (Federal Assistance Listing #84.268) Federal Award Number: P268K211875 Federal Pell Grant Program (Federal Assistance Listing #84.063) Federal Award Number: P063P211875 Federal Award Year: 2021-2022 Criteria: Under the Pell grant and U.S. Department of Education (?ED?) direct loan programs, institutions are required to report enrollment information via the National Student Loan Data System (?NSLDS?) (OMB No.1845-0035) (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. 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. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Condition, Context, and Sample Method: Due to an inconsistency between the Institute?s and NSLDS?s approach to calculating program lengths, from a sample selection of forty (40) students, we identified forty (40) students whose Published Program Length Measurement and Published Program Length were inaccurately reported. The auditor made the initial selection of forty (40) students using a nonstatistical approach that obtained a representative sample from across the population. Cause: The NSLDS Enrollment Reporting Guide provides a caution that institutions should report associate and bachelor degree programs in years and not months. When program length is reported in months or weeks, NSLDS uses this value along with the Weeks in Title IV Academic Year value to calculate a length in years. This resulted in program lengths that are too long. For thirty (30) of the students selected in our sample enrolled in the Institute for a bachelor?s degree program the Institute reported to the NSLDS a Reported Program Length of forty-eight (48) Months instead of four (4) years. This resulted in the Institute providing the NSLDS the information, along with a Weeks in Title IV Academic Year of thirty (30), to calculate and display a Published Program Length in Years of 6.857 years (48 multiplied by 30 divided by 30 multiplied by 7) instead of the correct period, four (4) years. Effect: The accuracy of the Published Program Length Measurement and Published Program Length in Years were inaccurately reported to the NSLDS for the forty (40) students selected for testing. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: The Institute should ensure that student Published Program Length Measurement is listed in years and that reported Program Length is calculated in years as recommended by the NSLDS Enrollment Reporting Guide so that the Published Program Length calculation is accurate to the true length of the program.