2023-003 US Department of Education
Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Explanation of disagreement with audit finding: There is no disagreement with the audit finding, but we offer the following explanation:
Identification of Errors and Corrections to New SIS:
• Conversion to a new SIS (Jenzabar - Jl) was effective November 2022, and forced subsequent Fall 2022 NSC Enrollment Transmittal Files to be created in the new system mid-term. The concern of enrollment report timing was brought to the vendor multiple times before the transition. However, due to scheduling limitations on the vendor's end, the transition to the new system had to be completed mid-term.
• In late May/early June we began end of term processing and reconciliations, and we identified that student status changes were not properly pulling the correct enrollment status information through the vendor's enrollment report creation process.
• Support tickets were sent to the vendor immediately to address the problems with the system process that creates NSC Transmittal Files.
• System configuration changes were made as recommended by the vendor to properly update enrollment status changes.
• Through the investigation of these configuration changes, additional system errors were identified that were not allowing some enrolled students to be properly pulled to the enrollment files.
• Support engagements continued with the vendor throughout July and August to identify and correct the system configuration to correctly pull enrolled students into the NSC Transmittal File. This was completed by the end of summer term, and the final summer enrollment file contained the correct number of students enrolled with the correct final enrollment status.
• Internal validation reports were created and executed to ensure that correct student data was transmitted on the Fall first of Term reports. We believe this transmission contained the correct number of students and the correct status. These internal validation reports will be conducted prior to all NSC submissions. Creation of new/additional reports will be conducted as necessary.
• We have been able to verify that the Fall 2023 subsequent term enrollment file did contain accurate status change information, and this issue is now resolved.
• By correcting status change configurations, we have also identified that program begin dates converted from the old SIS to the new SIS were incorrectly mapped.
• We are currently in the process of identifying the ID#s with incorrect program begin dates and making manual updates to the students' record in the new SIS environment. The vendor has not provided a clear path to programmatically correct this in bulk, so this record validation is being completed one-by-one manually. We project to have this completed for currently enrolled students by the final fall 2023 enrollment submission.
Correcting previously submitted data:
• We reached out to our Data Analyst, Elizabeth Fennessy, with the National
Student Clearinghouse, to begin working on a corrective action for the missing status change data.
• Elizabeth consulted with the NSC Audit Resource Team, and the following
plan was recommended to MACC:
• For students Less Than Half Time Spring 2023 or Withdrawn Spring 2023 that re-enrolled Summer 2023, these would be a manual update in NSLDS for Title
IV students in these scenarios using NSLDS site 'Enrollment History Update.'
• Later in Clearinghouse, the same update can be reflected using Clearinghouse site 'Student Look-Up' to bring the record current with
updated enrollment reflected Spring 2023. By updating NSLDS first, that will avoid an NSLDS error "certification date out of sync" (error code 32).
• MACC prepared reports to retrieve students meeting the criteria identified
above.
• These students' enrollment statuses for Spring 2023 and Summer 2023 have been manually updated in NSLDS Enrollment History Update and in NSC
Student Look-up to bring these enrollment statuses up to date; this has been a long and time-consuming process.
• We are also currently working on reports to identify students that were enrolled in spring 2023 but missed when the NSC Enrollment Transmittal File
was created. We believe that students missed in Summer 2023 have been brought up to date through the submission of the corrected final Summer 2023 Enrollment File (to include students that were also enrolled in Spring 2023). Any student that was inadvertently excluded from the Spring 2023 and has not been brought up to date through subsequent corrected submissions, will be manually corrected through NSC Student Look-Up, and NSLDS Enrollment History Update if necessary.
• We also reached out to l<athy Feith, Branch Chief, l<C School Participation Division, Federal Student Aid, U.S. Department of Education; she is aware of our issues. She recommended making enrollment changes directly in NSLDS for students who withdrew.
Action taken in response to finding: The following is our Corrective Action Plan.
• The Registrar will review data in J1 and submit enrollment records to NSC each month.
o The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly.
o MACC will continue to work with Jenzabar for a solution for reporting last dates of attendance for students who are withdrawn from all classes.
• After the enrollment file is accepted by NSC, 20 randomly selected students will be verified for accuracy.
• The selection will be made by the Director of FA and/or Registrar.
• The selection will include students who have withdrawn from all classes and had an R2T4 calculation performed.
• The Registrar, or designee, will review the data in NSC.
• The Associate Director of Financial Aid, or designee, will review the data in NSLDS.
• Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up.
• The records will be maintained in a designated Teams folder.
Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar).
Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.