Finding 387665 (2023-002)

Significant Deficiency Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299743
Organization: Saint Leo University, INC (FL)

AI Summary

  • Core Issue: The University failed to accurately report student program dates to NSLDS, with 24 out of 40 cases showing discrepancies.
  • Impacted Requirements: Compliance with 34 CFR 685.309 and 34 CFR 690.83, which mandate timely and accurate enrollment reporting.
  • Recommended Follow-up: Review and improve reporting procedures to ensure accurate data submission to NSLDS and timely corrections of errors.

Finding Text

2023–002 – NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 – Federal Direct Student Loans Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Other Matters Finding related to Compliance and Significant Deficiency in Internal Controls over Compliance. Criteria or Specific Requirement: Institutions are required to report, certify, and correct enrollment information under the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (34 CFR 685.309). 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. Institutions must return the roster within 15 days of receipt, and correct errors within 10 days of receipt. 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. Condition: During our testing of the Direct Loan programs, we selected a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 24 of 40 students tested had one or more instances of noncompliance noted below: I. Twenty-four instances where the student’s program begin date reported to NSLDS did not agree to the Institution's records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. One instance where the student’s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned Costs: None Context: Out of a sample of 40 students selected for testing we noted the exceptions as described above. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: YES Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.

Corrective Action Plan

NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The university completed phase one of the corrective action plan with the practice of matching the program begin date to the term date for new students last year. Accuracy is monitored with reports. No repeat findings found on this population of students. The audit recommendation focuses on continuing students. The university is now in the process of completing phase two, continuing students. Existing active programs will be manually updated by the Registrar’s Office; steps for resolution are already in progress. Using reports to capture students, the team will update the student information system, NSLDS, and NSC, correcting the program begin date to match the term date. This process change will align our reporting procedures with required regulations prior to the close of the 2023 fiscal year (July 2024). 2) The Registrar’s team will provide ongoing instruction to all personnel who have access to process program changes in the student information system. The instructions will direct users to match the begin date of the new program with the term; exceptions will be addressed in the communication. Changes will be monitored by the Registrar’s Office with daily reports. Repeat finding, see 2022-003, item 2. CAP phase 2 focuses on continuing students and is still in process, this involves identifying continuing students with mis-matched data and making the appropriate corrections. Name(s) of the contact person(s) responsible for corrective action: Elizabeth Vestal, Registrar. Planned completion date for corrective action plan: July 2024

Categories

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

Other Findings in this Audit

  • 387663 2023-001
    Significant Deficiency Repeat
  • 387664 2023-001
    Significant Deficiency Repeat
  • 964105 2023-001
    Significant Deficiency Repeat
  • 964106 2023-001
    Significant Deficiency Repeat
  • 964107 2023-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $57.08M
84.063 Federal Pell Grant Program $14.79M
84.007 Federal Supplemental Educational Opportunity Grants $1.07M
84.033 Federal Work-Study Program $571,862
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $218,305
47.076 Education and Human Resources $136,493
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $76,379