Finding 384321 (2023-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-25
Audit: 297439
Organization: Erikson Institute (IL)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: 50% of students tested had mismatched enrollment statuses reported to NSLDS.
  • Impacted Requirements: Noncompliance with CFR sections 685.309 and 690.83(b)(2) regarding timely reporting of student status changes.
  • Recommended Follow-Up: Enhance internal controls to ensure accurate and timely reporting to NSLDS.

Finding Text

Finding 2023-002—Enrollment Reporting Repeat Finding: Yes Federal Program Title—U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loans: 84.268 Federal Award Year 2022-2023 Condition For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Criteria CFR section 685.309 and 690.83(b)(2) requires the Institute to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure accurate reporting of enrollment status changes. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Between 2022 and 2023, the Registration & Records office at Erikson experienced significant staff turnover, which revealed underlying vulnerabilities. Initially, there was a reorganization of the entire enrollment management function. During this time, a key office member was out for extended periods of time under FMLA prior to resigning in spring 2023. This staffing shortage led to delays in registration functions related to reporting to the NSLDS that sit within this office, including reporting. Context Two out of four students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the Institute improve internal controls in order to report any status changes to the NSLDS timely and accurately. Views of Responsible Officials We agree with this finding. See corrective action plan. Finding 2023-002—Enrollment Reporting Repeat Finding: Yes Federal Program Title—U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loans: 84.268 Federal Award Year 2022-2023 Condition For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Criteria CFR section 685.309 and 690.83(b)(2) requires the Institute to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure accurate reporting of enrollment status changes. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Between 2022 and 2023, the Registration & Records office at Erikson experienced significant staff turnover, which revealed underlying vulnerabilities. Initially, there was a reorganization of the entire enrollment management function. During this time, a key office member was out for extended periods of time under FMLA prior to resigning in spring 2023. This staffing shortage led to delays in registration functions related to reporting to the NSLDS that sit within this office, including reporting. Context Two out of four students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the Institute improve internal controls in order to report any status changes to the NSLDS timely and accurately. Views of Responsible Officials We agree with this finding. See corrective action plan.

Corrective Action Plan

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Registration, & Records, who oversees the Registration & Records office has taken steps to ensure timely and accurate reporting moving forward. In summer 2023, a new full-time Registrar was hired to oversee the office. Additionally, Erikson has updated the functioning of its student information system in ways that are compatible with timely and accurate reporting. Changes to the system have been tested and implemented. Lastly, Erikson created a new Business Analyst position and is in the process of hiring to oversee administration and maintenance of the student information system in ways that will continue to facilitate timely reporting and data integrity. Contact Person Leanne Beaudoin Ryan, PhD Director of Research, Registration, & Records lbeaudoinryan@erikson.edu Anticipated Completion Date Updates to processes and procedures were completed in September 2023. Transition from outsourced staffing to the newly-created position is expected by May 2024.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 384318 2023-001
    Significant Deficiency
  • 384319 2023-001
    Significant Deficiency
  • 384320 2023-001
    Significant Deficiency
  • 384322 2023-003
    Significant Deficiency
  • 960760 2023-001
    Significant Deficiency
  • 960761 2023-001
    Significant Deficiency
  • 960762 2023-001
    Significant Deficiency
  • 960763 2023-002
    Significant Deficiency Repeat
  • 960764 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.55M
93.600 Head Start $612,255
84.305 Education Research, Development and Dissemination $300,245
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $220,511
84.425 Education Stabilization Fund $211,666
93.575 Child Care and Development Block Grant $191,160
93.434 Every Student Succeeds Act/preschool Development Grants $121,893
84.033 Federal Work-Study Program $75,000
45.313 Laura Bush 21st Century Librarian Program $61,836
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $2,515