Finding Text
2022-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and significant deficiency in internal control over compliance relating to special tests Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. Questioned Costs: Questioned costs could not be determined. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The Institute?s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management?s Response: Management agrees with the finding. Through internal investigation, it was determined that the issue arose through National Student Clearinghouse (NSC), which reports the Institute?s data to NSLDS. Management will work with NSC to assure graduates are accurately reported as soon as possible within existing external systems. The changes to management?s enrollment reporting procedures will be added to the Institute?s NSC submissions procedure documentation.