Finding 386155 (2023-001)

-
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-27
Audit: 298575
Auditor: Baker Tilly

AI Summary

  • Core Issue: The Corporation failed to notify the NSLDS on time for 4 students with status changes, impacting compliance with Title IV regulations.
  • Impacted Requirements: Institutions must update and return enrollment information to the Secretary promptly and notify of any significant changes within specified timeframes.
  • Recommended Follow-Up: Review and improve procedures for reporting student status changes to ensure timely notifications to the NSLDS.

Finding Text

Criteria: Title IV regulations (34 CFR Section 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) 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, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The Corporation did not notify the National Student Loan Data System (NSLDS) in a timely manner for 4 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The Corporation's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect or Potential Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendations: We recommend that the Corporation review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the Corporation. Management Response: Management concurs with the finding and the Corporation will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

Corrective Action Plan

Response to Finding 2023-001: Status Changes Management Response Saint Vincent College concurs with the finding of delays in reporting changes of student enrollment status to the National Student Loan Data System (NSLDS) and attributes the delays to 1.) the first cohort of a joint program with another institution reaching completion 2.) a data breach reported by National Student Clearinghouse (NSC) in June 2023. All students identified as being reported outside of the required time period are enrolled in the joint Bachelor of Science degree in Nursing between Saint Vincent College and Carlow University that began in Fall 2019. Under the agreement for this program, the Registrar’s office of Saint Vincent College reports enrollment to the NSLDS via the NSC. Students graduate with a Carlow University degree. Saint Vincent College is to report program completers as withdrawn at the end of the final enrollment period and Carlow University is to report the students as graduated. The first cohort through this arrangement completed the program requirements in May of 2023. The students in this cohort were not included with the other student enrollment status changes reported in May 2023 following the end of the semester/graduation. While Saint Vincent did ultimately report the cohort as withdrawn, it occurred outside of the required time frame. Saint Vincent’s primary method of reporting status changes to the NSLDS is through the NSC. The NSC reported a data breach on June 26, 2023, at which point the College’s IT department instructed the Registrar to immediately stop sending data to the NSC. The resulted in the aforementioned cohort of students not being reported to the NSC or NSLDS until September 2023 when the College’s IT department provided approval for the Registrar to resume sending data to the NSC. Corrective Action Beginning March 1, 2024, Saint Vincent College’s Financial Aid Office in conjunction with Registrar’s office has implemented a 45-day report to verify that all withdrawals and completions have reached NSLDS via the National Student Clearinghouse. The discovery of any that did not reach NSLDS will be manually reported directly on the NSLDS platform to avoid being outside of the 60-day requirement. Further, during any period of known issues/outages of NSC, the College will report status changes directly to NSLDS. Conclusion The College deems that the corrective action steps outlined above will sufficiently resolve the findings and prevent any future instances of untimely reporting of enrollment data to the NSLDS. Responsible Party, Joshua A. Guiser, CPA. Vice President for Finance and Treasurer Chief Financial Officer

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $13.23M
84.063 Federal Pell Grant Program $1.90M
84.031 Higher Education_institutional Aid $706,067
84.038 Federal Perkins Program $488,926
93.959 Block Grants for Prevention and Treatment of Substance Abuse $457,712
84.425 Education Stabilization Fund $268,408
84.007 Federal Supplemental Educational Opportunity Grants $221,296
84.042 Trio_student Support Services $217,949
93.600 Head Start $201,599
84.033 Federal Work-Study Program $193,027
93.788 Opioid Str $85,992
59.037 Small Business Development Centers $84,788