Finding 376044 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-14

AI Summary

  • Core Issue: The College failed to report a student's enrollment status change to NSLDS within the required 60-day timeframe, with a delay of 76 days.
  • Impacted Requirements: Compliance with 34 CFR 685.309(b)(2) and 2 CFR Part 200, Appendix XI, which mandate timely reporting of enrollment changes.
  • Recommended Follow-Up: Provide training for staff on NSLDS reporting requirements and consider submitting additional rosters to improve compliance.

Finding Text

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Clusters AL #’s: 84.268 Award year: 2023 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] 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 – (i) 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; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 1 student, out of a sample of 40, was not reported to NSLDS within the required timeframe by 76 days. Cause The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The College did not report the student’s status change to NSLDS within the required timeframe, which may impact the student’s loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Clusters AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The College will be looking at making some business process changes to review files submitted to NSC(National Student Clearing House) and NSLDS (National Student Loan Data Service) on a monthly basis and perform monthly reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan: This new procedure was implemented starting with the Fall 2023 semester and beyond. Contact Person Alex Jean-Jacques Director of Financial Aid of Operations

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 952486 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $3.70M
84.268 Federal Direct Student Loans $1.89M
84.031 Higher Education_institutional Aid $428,018
84.007 Federal Supplemental Educational Opportunity Grants $182,567
11.307 Economic Adjustment Assistance $157,484
84.048 Career and Technical Education -- Basic Grants to States $139,743
84.033 Federal Work-Study Program $57,642
47.076 Education and Human Resources $25,022
84.425 Education Stabilization Fund $25,000
17.261 Wia Pilots, Demonstrations, and Research Projects $23,965
12.630 Basic, Applied, and Advanced Research in Science and Engineering $11,065
94.006 Americorps $5,256