Finding 25854 (2022-001)

2022-001: National Student Loan Database System (NSLDS) Reporting Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.268 ? Federal Direct Loan Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days Condition: During our testing, we noted 1 of the 8 students tested were reported to NSLDS in which the status per the Program Enrollment did not match the Campus Enrollment as well as the Seminary's records. There was also 1 of 8 students tested where the student's effective enrollment date report to NSLDS did not match the Seminary's records. Questioned Costs: None Context: During our testing, it was noted the Seminary did properly report the status change at the Program Enrollment level. Furthermore, there was an error of the effective date for the students withdrawal reported to NSLDS. Cause: The Seminary did not determine unofficial withdrawals correctly and did not properly report student statuses to NSLDS. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By reporting an incorrect effective date, the grace period begin date for the student will be incorrect. The Seminary also did not comply with Department of Education (ED) regulations requiring reporting student enrollment status change to NSLDS within 60 days. Repeat Finding: Yes, 2021-001 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the Seminary's last date of attendance. Views of Responsible Officials: There is no disagreement with the audit finding.