Finding 26016 (2022-004)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 24461
Organization: Laboure College of Healthcare (MA)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The College failed to timely and accurately report enrollment status changes for 2 out of 40 students to the NSLDS, exceeding the 60-day requirement.
  • Impacted Requirements: Compliance with federal regulations for enrollment reporting under the Pell Grant and Direct Loan programs, specifically 34 CFR 690.83(b)(2) and 34 CFR 685.309.
  • Recommended Follow-Up: Review and enhance internal controls to ensure timely and accurate reporting of enrollment changes, and verify that submitted data reflects current student statuses.

Finding Text

Finding No. 2022-004 ? Enrollment Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 2 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The College was notified of the students? enrollment status change from three-quarter time to ?withdrawn?. Accordingly, the students? status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred 72 days for one student and 74 days for the other student from the date of status change. Questioned Costs: None. Prevalence: Identified in 2 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Cause: The College?s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.

Corrective Action Plan

Finding: No. 2022-004 Enrollment Reporting Finding: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Corrective Action Taken or Planned: The College, more importantly the Financial Aid Director, Erin Hanlon will review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner, effective immediately. Additionally, a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Enrollment reporting corrections have been corrected as of 03/29/2023.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 26017 2022-005
    Significant Deficiency
  • 26018 2022-004
    Significant Deficiency
  • 26019 2022-002
    Significant Deficiency Repeat
  • 26020 2022-003
    Significant Deficiency
  • 26021 2022-002
    Significant Deficiency Repeat
  • 26022 2022-005
    Significant Deficiency
  • 26023 2022-005
    Significant Deficiency
  • 26024 2022-005
    Significant Deficiency
  • 602458 2022-004
    Significant Deficiency
  • 602459 2022-005
    Significant Deficiency
  • 602460 2022-004
    Significant Deficiency
  • 602461 2022-002
    Significant Deficiency Repeat
  • 602462 2022-003
    Significant Deficiency
  • 602463 2022-002
    Significant Deficiency Repeat
  • 602464 2022-005
    Significant Deficiency
  • 602465 2022-005
    Significant Deficiency
  • 602466 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $9.33M
84.063 Federal Pell Grant Program $2.20M
93.364 Nursing Student Loans $465,874
84.007 Federal Supplemental Educational Opportunity Grants $163,369
84.038 Federal Perkins Loan Program $103,649
84.425 Education Stabilization Fund $20,153
84.033 Federal Work-Study Program $14,571