Finding 372379 (2023-002)

Significant Deficiency Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-05

AI Summary

  • Core Issue: The University of Students failed to report enrollment status accurately and on time, violating federal regulations.
  • Impacted Requirements: Compliance with 34 CFR 682.610, which mandates accurate enrollment reporting every 60 days and timely responses to NSLDS.
  • Recommended Follow-Up: Review and update enrollment reporting policies and procedures to ensure compliance and prevent future discrepancies.

Finding Text

Federal Agency: Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.063, 84.007, 84.379, 84.268 Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P268K230377 (Direct Loan 2023) Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: Incorrect or untimely reporting by the University of Students’ Changes in status during the 2020-2021 award year under audit. Questioned costs: Unknown. Context: Out of the 17 students tested noted 1 or more discrepancies, as follows:  2 students’ status was incorrectly reported to NSDLS.  1 student’s’ enrollment effective date was not reported correctly to NSLDS.  1 students’ enrollment status change was not reported to NSLDS within 60 days. Cause: Lack of appropriate policy and procedure in place regarding NSLDS enrollment reporting for the year under audit. Effect: Noncompliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: Yes – 2022-004 Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Corrective Action Plan

NSLDS Enrollment Reporting (repeat) Finding: As noted in the audit report, there were 4 discrepancies found in 17 files in which student information reported to NSLDS was incorrect or untimely. • 2 students' status was incorrectly reported to NSLDS. • 1 student's enrollment effective date was not reported correctly to NSLDS. • 1 student's enrollment status change was not reported to NSLDS within 60 days. Auditors' Recommendation: The University should review their enrollment reporting policies and procedures to ensure accurate reporting. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: There were two files in which NSLDS reporting errors were found. Student #12 was withdrawn per their school transcript effective 5/14/2023, however, the enrollment status was reported at NSLDS as Less Than Half Time as of 5/8/2023. Student #14 was in a Graduate status on their transcript but was reported as Withdrawn on NSLDS. Also, the student's status was reported 134 days after the status change event. Status changes must be reported to NSLDS within 60 days. The instances for this finding occurred during a time when there was a staffing change in the registrar's office and a new registrar had not yet transitioned into the position. Since this time, a new registrar, Natalie Brown-Motes, was hired, and the process has been reviewed with Assistant Registrar, Lara Ellison, to ensure that there is a back up plan if the registrar is unavailable to complete this process. Additionally, the school switched to a new Student Information System (SIS), Colleague, which was implemented beginning with the Fall semester 2023. The new SIS works with the National Student Clearinghouse enrollment reporting service. In order to ensure timely reporting, the registrar's office creates an enrollment report in Colleague each month. That report is transmitted to Clearinghouse which uses the information to update the enrollment data in NSLDS. If there are any possible errors that need to be reviewed, the registrar receives a report on Clearinghouse of any errors so they can be reviewed and approved or corrected. The error report must be completed within two weeks of receipt. Colleague only reports to Clearinghouse students who have actually registered for classes. Previously, enrolled students who had not registered were included in the report. This inclusion regularly generated additional errors. Since the new system improves the reporting process so only registered students are reported, there is less opportunity for error. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Natalie BrownMotes and Assistant Registrar, Lara Ellison Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on National Student Clearinghouse process with Colleague completed September 23. • Began using Colleague system to report enrollment data to NSLDS through National Student Clearinghouse in September 2023.

Categories

Student Financial Aid Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 372378 2023-001
    Significant Deficiency Repeat
  • 372380 2023-003
    Significant Deficiency
  • 372381 2023-004
    Significant Deficiency
  • 372382 2023-001
    Significant Deficiency Repeat
  • 372383 2023-002
    Significant Deficiency Repeat
  • 372384 2023-003
    Significant Deficiency
  • 372385 2023-004
    Significant Deficiency
  • 372386 2023-001
    Significant Deficiency Repeat
  • 372387 2023-002
    Significant Deficiency Repeat
  • 372388 2023-003
    Significant Deficiency
  • 372389 2023-004
    Significant Deficiency
  • 372390 2023-001
    Significant Deficiency Repeat
  • 372391 2023-002
    Significant Deficiency Repeat
  • 372392 2023-003
    Significant Deficiency
  • 372393 2023-004
    Significant Deficiency
  • 948820 2023-001
    Significant Deficiency Repeat
  • 948821 2023-002
    Significant Deficiency Repeat
  • 948822 2023-003
    Significant Deficiency
  • 948823 2023-004
    Significant Deficiency
  • 948824 2023-001
    Significant Deficiency Repeat
  • 948825 2023-002
    Significant Deficiency Repeat
  • 948826 2023-003
    Significant Deficiency
  • 948827 2023-004
    Significant Deficiency
  • 948828 2023-001
    Significant Deficiency Repeat
  • 948829 2023-002
    Significant Deficiency Repeat
  • 948830 2023-003
    Significant Deficiency
  • 948831 2023-004
    Significant Deficiency
  • 948832 2023-001
    Significant Deficiency Repeat
  • 948833 2023-002
    Significant Deficiency Repeat
  • 948834 2023-003
    Significant Deficiency
  • 948835 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.21M
84.063 Federal Pell Grant Program $3.09M
84.007 Federal Supplemental Educational Opportunity Grants $66,406
84.033 Federal Work-Study Program $54,868