Finding Text
FINDING 2022-001 Special Tests and Provisions ? Enrollment Reporting ? Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Federal Assistance Listing Numbers: 84.268, 84.063 Federal Program Name: Federal Direct Student Loans and Federal Pell Grant Program Award Year: 2021-22, 2020-21, 2019-20, 2018-19 Criteria: Uniform Guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to the National Student Loan Data System (NSLDS) within at least 60 days of when the student attendance change occurs. It is the College?s responsibility to update students? enrollment information timely and accurate as outlined in 34 CFR section 685.309. In accordance with electronic announcement ID: General-23-04, auditors were not expected to include any enrollment reporting data due from July 19, 2022 through February 28, 2023 in their evaluation of the institution?s compliance with the enrollment reporting requirements. Condition and context: A sample of 26 students who were borrowers of Federal Direct student loans and recipients of Pell Grants and had withdrawn or graduated from the College during the 2021-2022 fiscal year were selected. The enrollment information and withdrawal or graduation date per the College's records was compared to the information reported to the NSLDS. In our sample, we noted that 1 withdrawn student who was a Federal borrower or Pell recipient were considered as withdrawn by the College, however the attendance change was not reported to NSLDS. In addition, 5 students who were Federal borrowers and Pell recipients were considered as withdrawn or graduated from the College during the 2021-2022 fiscal year, however the students? status change were not reported to NSLDS within the 60 day requirement. All 6 instances were outside of the period of July 19, 2022 through February 28, 2023 and as such are not excluded from our evaluation of the institution?s compliance with the enrollment reporting requirements under electronic announcement ID: General-23-04. Random, not statistical, sampling was used. Questioned costs: None. Cause: This occurred because of lack of controls and oversight of the process. Effect: This resulted in late reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding: Yes, 2021-001 Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend a review of roles and responsibilities surrounding this process be evaluated and, if deemed necessary, revised. Lastly, we recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the NSC submissions. Views of responsible officials and planned corrective actions: The College concurs with this finding. Since last year, the College has initiated a multi-tiered corrective action plan to address this finding from the prior year. We were able to complete many steps of the plan within the 2021-2022 year, leading to a much higher rate of compliance during the year under audit. We will continue with this plan, with the goal of full compliance. As outlined in the prior finding status comment, we have initiated and completed the following: ? Initiated Campus-wide Corrective Action Plan Enrollment Reporting Project to document processes and procedures to facilitate reporting responsibilities and cross-training of Student Services employees related to the various steps of enrollment reporting. ? Campus stakeholders researched and reviewed relevant policies, procedures and processes to mitigate enrollment reporting errors. ? Hired full-time Registrar ? Restructured Financial Aid to bring aboard Processing Coordinator and an additional Advisor ? Initiated search for database support position to assist with Student Service systems issues, including any dealing with Enrollment Reporting (search is still underway as of 2-28-2023.) Moving forward, our plan from last year is progressing, with the Vice-President of Student Services currently in the process of training the Registrar on the now updated and documented Enrollment Reporting processes and procedures, and in the compliance regulations which apply to the reporting. The Vice-President will continue to oversee the Enrollment Reporting, until such time that the training is complete, at which time the Vice-President will fully transfer Reporting to the Registrar and monitor the Registrar?s reporting for compliance until the institution is cleared of this finding.