Finding Text
Finding 2023-001 Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster Federal Award Year: 2022-2023
Criteria and Context: Under the Pell grant and U.S. Department of Education (“ED”) direct loan programs, institutions are required to report enrollment information via the National Students Loan Data System (“NSLDS”) (OMB No. 18450035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An 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 the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition and Sample Method: From a non-statistical sample of forty (40) students tested who graduated, withdrew, or otherwise had an enrollment status change during the year, we identified one (1) student whose Graduated status was reported to the NSLDS more than 60 days after the students’ respective Graduation date (143 days late). Cause: While the College has established policies and procedures to ensure that the required reports are accurately completed and submitted on a timely basis to the NSLDS, we noted oversight on the timely reporting for one (1) graduated student. This resulted in the College missing the 60-day timing requirement for NSLDS reporting and resulted in the non-compliance noted. Effect: There is a delay in the NSLDS obtaining the required information regarding the enrollment status changes of students. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: We recommend that management ensure that staff who will be submitting data to the NSLDS are aware of the compliance requirements and the appropriate level of timely review happens for student status changes
to ensure they are timely submitted to NSLDS without exception. Views of Responsible Officials and Planned Corrective Action: Responsible Officials: Dr. Raye Thompson, Executive Director of Enrollment Management Operations and Compliance Tarsha D. Washington Director, Office of Student Records and Registration Corrective Action: 1. The Associate Director of Academic Records will certify enrollment every 30 days to ensure timely submission to NSLDS. 2. The Associate Director of Academic Records will identify and resolve all errors identified by NSLDS, which will be resolved within ten days. 3. Winter graduates will be placed on a schedule to ensure timely submission and reporting to NSLDS. 4. The Associate Director of Academic Records will be responsible for completing all National Clearinghouse training and providing training to staff members involved in the reporting submission to ensure that all information is collected and reported promptly. 5. Regular internal audits will be scheduled and conducted to identify improvement areas to ensure enrollment reporting compliance. Individual Responsible for Corrective Action: Charletha C. Porter, Associate Director Academic Records
Anticipated Completion Date for Corrective Action: Completed - Process corrected as of January 2024