Finding 372626 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-06
Audit: 293677
Organization: Holy Family University (PA)

AI Summary

  • Core Issue: The University failed to update the enrollment status of graduated students in the National Student Loan Data System (NSLDS), leading to inaccurate Title IV loan records.
  • Impacted Requirements: Compliance with 34 CFR 685.309(b) regarding timely updates of student enrollment statuses and reporting to the Secretary.
  • Recommended Follow-Up: Implement procedures to ensure accurate reporting of status changes and effective dates to NSLDS, including internal tracking of students' status changes.

Finding Text

ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Federal Award Identification Number: P268K232105; P063P222105 Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass Through Entity: Not applicable Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For one graduated student tested, the University reported the student as withdrawn to the National Student Loan Data System (NSLDS) while they were confirming degree complete. However, once the student did graduate, the University did not update their status to graduated in NSLDS. For another graduated student, their status was not updated within NSLDS, as they were continuing to a graduate program at the University in the following semester. While the student remained correctly reported as full-time on the campus level reporting, the University did not appropriately report the graduated status for program level reporting within NSLDS. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The University identified a gap in procedures regarding reporting status changes upon confirming degree completion. The University needs a process in place to identify and report non-traditional graduates. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate reports internally to track all students' whose status changed and verify against the roster submitted to NSLDS. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management Response: The University understands the importance of accurate enrollment information. The status for the first student has been corrected from withdrawn to graduated. The student was reported correctly after the end of the Fall 2022 semester as withdrawn since they had not fully completed their degree requirements. The graduation status for the second student was updated to graduated for their undergraduate degree as they continue full-time in their graduate degree program at the University.

Corrective Action Plan

ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate reports internally to track all students' whose status changed and verify against the roster submitted to NSLDS. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Action Taken: We have strengthened our procedures for our NSLDS report verification process as we continually strive to comply with all regulations. Once the Ellucian NSC graduation report is run, the Registrar's Office will compare that against at least 10 % of the students on the graduation list to ensure accuracy. There are six times a year that the graduation process occurs. If a student is no longer enrolled but has not completed degree requirements (i.e. takes an incomplete in a course), they would be reported as withdrawn during the next semester. However, once they complete their degree requirements and officially graduate, they will get reported as "graduated" on the next graduation run. Since these students are processed manually, the Registrar's Office will maintain a listing of the "non-traditional graduates" (i.e. finishes degree requirements outside of the six standard times per year) and verify their status is recorded correctly in NSLDS. They will also compare at least 10% of the students on the course drops and withdraw report against the status and date generated by the Ellucian NSC report to ensure accuracy. The Registrar's Office will also realign the NSC reporting schedule for graduating students to align with our processing schedule beginning with the Spring 2024 semester.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 949068 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $21.29M
84.063 Federal Pell Grant Program $4.46M
93.364 Nursing Student Loans $815,957
84.038 Federal Perkins Loan Program $408,603
84.425 Education Stabilization Fund $407,118
84.007 Federal Supplemental Educational Opportunity Grants $405,189
84.031 Higher Education_institutional Aid $391,998
93.575 Child Care and Development Block Grant $209,620
84.033 Federal Work-Study Program $133,977
93.264 Nurse Faculty Loan Program (nflp) $50,703
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $22,035
84.027 Special Education_grants to States $10,000