Finding 381228 (2023-003)

Finding 2023-003 – Enrollment Reporting – Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Perkins Loan Program and 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2022 – June 30, 2023 Criteria: Per 34 CFR 685.309, institutions with direct loan programs must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file, and report accurate Campus-Level and Program-Level Enrollment Data separately at least every 60 days or within 60 days of the student's status change. This is for the purpose of providing complete and accurate data to lenders regarding enrollment status so they may properly determine when repayment of the loans should begin. Condition and Context: During our Enrollment Reporting testwork over 40 students that received loans under Title IV and ceased to be enrolled on at least a halftime basis, went on leave of absence, graduated, or withdrew, we noted the following: • 38 student enrollment status change effective dates reported to NSLDS at the Program Level did not agree with Whittier’s internal records or to the Campus Level report. • 2 student enrollment status changes were not reported to NSLDS within the required 60-day timeframe. Isolated or Systemic: Systemic. Cause and Effect: The College’s control failed in detecting that untimely information was reported to NSLDS. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. View of Responsible Officials: The Office of the Registrar concurs with this finding. As of September 2023, Whittier College has adjusted the transmission schedule of enrollment reports to the National Student Clearinghouse to meet the guidelines set forth by NSLDS. Whittier College will submit enrollment files to the National Student Clearinghouse on the 30th of every month, with the exception of the December end of term enrollment report, which will be submitted on the Friday before the last working day before the holiday break. Degree Verify reports will be submitted to the National Student Clearinghouse within two weeks of the conferral date of every term to ensure the timeliness of status change submissions to NSLDS. Whittier College will also correct error reports and resubmit within the 10 days indicated by NSLDS to ensure compliance.