Finding Text
Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance. Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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 are responsible for timely reporting, whether they report directly or via a third-party servicer. 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). Condition and Context : We selected forty students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exception: For one enrollment status change, the status change was not reported within 60 days, but rather 139 days. Based on this finding management performed an analysis to identify other impacted students. An additional 13 students with the same circumstances were identified. Cause: The students involved in this finding were all students who graduated later than the majority of the University. The University submitted graduation status changes to the National Student Clearinghouse (NSC) on June 7, 2023. Any graduations determined after that date were to be reported manually to the NSC as had always been done. The University attempted to submit the late graduations, but the NSC had locked the record because of an unprocessed file. Due to that delay, that submission was overlooked both by the Associate Director who was notified of the late graduations and by the Compliance Associate responsible to review the edit reports. The July 2023 edit report generated to capture late graduations was generated on July 10, 2023. The review took place for students who graduated late (between June 9 and July 10). These 14 students graduated on June 12, 2023 were overlooked. Effect: Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures to ensure that student enrollment changes are accurately reported to NSLDS within 60 days of the status change. The University should provide training to the departments responsible for the accuracy and timeliness of this reporting. Views of Responsible Official: Management agrees with the recommendation. Corrective action by Associate VP of Enrollment Services and University Registrar is as follows: The Office of Enrollment Services has a supplemental procedure in place to capture students who graduate after the initial file submission to the National Student Clearinghouse. To avoid any oversight in the future, the Office of Enrollment Services will enhance the edit report process and frequency. Effective immediately, the edit report will be generated by date span and generated every thirty days by the Compliance Officers to ensure all manual updates to a prior graduation are captured within the sixty-day allowance.