February 28, 2024
Audit Response to Finding 2023-001 to Uniform Guidance Audit - Enrollment reporting to National Student Clearinghouse
Analysis:
During the spring 2023 graduate only submission to the National Student Clearinghouse (NSC), Robert Morris University (University) incorrectly queried the wrong student population of graduates from Banner (student information system) as a result of human error, which resulted in the untimely reporting of spring 2023 graduates to the NSC.
There were also exceptions found attributable to off-cycle graduates who had degrees conferred but the University had not updated their status to “graduated” in the NSC in a timely manner. Upon further review, the University determined extenuating circumstances (i.e. completion of all paperwork, and assignments, incomplete grade(s) existed for these students’ and their graduation date fell outside of the normal graduation date of their peers for that semester cohort. Since the University only typically submits graduate only files to the NSC three times a year (Spring, Summer, and Fall), these students were not reported to the NSC in a timely manner.
Based on the findings noted above - and in the prior year Uniform Guidance audit, Robert Morris University (University) voluntarily undertook an exercise to self-audit the accuracy of all clearinghouse data submissions dating back to the implementation of the Banner Student Information System (SIS) in Fall 2021. At the conclusion of the self-audit, 127 students were found to have records of enrollment at the University, but were excluded from clearinghouse submissions during the period (July 2021 - November 2023) under self-audit. The University determined the omissions to be a combination of several factors; including, initial limitations in reporting capabilities as result of the Banner SIS conversion in Fall 2021 and overall process regarding review and submission of clearinghouse data.
Response:
Graduate Reporting
The spring 2023 graduate file submission error was identified internally by RMU in July 2023 and all spring 2023 graduates were reported to the NSC at that time - albeit untimely. The University deemed this to be an isolated incident.
For the off-cycle graduate exceptions, the University is increasing the frequency of submissions to the NSC to include mid-term submissions in addition to the end of semester submissions as usual practice. By increasing the frequency of submissions, the University believes this will capture the off-cycle graduates in a timely manner. Expected completion prior to May 31, 2024.
Lookback Analysis
As of the date of this letter, RMU has corrected all but 15 of the 127 errors and is working directly with representatives from the National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) to resolve the remaining 15 errors as soon as possible. Expected completion prior to May 31, 2024.
As a result of the findings noted above, the University’s Office of Data and Analytics (UDA) independently reviews all NSC files/extractions (graduate only and monthly enrollment reporting) from Banner prior to submission to the NSC. A member of UDA cross references the NSC file’s/extractions with other Banner student enrollment information for that time period to make sure the file is complete and accurate. The Registrar only submits files to the NSC after approval by the UDA and reports submission results back to the UDA after they are processed by the NSC.
Conclusion:
The University deems that the correction action steps outlined above will sufficiently resolve the findings and prevent any future instances of untimely reporting of enrollment and graduate data to the NSC and the NSLDS.
Regards,
Keith A. Roeper
Chief Financial Officer and Vice President for Business Affairs
Responsible Party