Finding Text
Finding No. 2023-001 - Special Tests and Provisions – Enrollment Reporting
Federal Program
Students Financial Assistance Programs Cluster:
Assistance Listing 84.063 - Federal Pell Grant Program
Assistance Listing 84.268 - Federal Direct Student Loans Program
Name of Federal Agency
U.S. Department of Education (USDE)
Pass-through Entity
N/A
Criteria
The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients.
The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program.
A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. 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
In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-six (26) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2023.
As a result of our test, we noted that for one (1) out of twenty-five (25) students that received Student Financial Assistance funds, or 4% of the applicable sample, the University did not report to the NSLDS the students’ status change within the required 60 days’ period.
Context
Of the 94 instances of status changes, we selected twenty-six (26) students (of which, twenty-five (25) had received Student Financial Assistance funds) and determined that for one (1) out of twenty-five (25) students that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements.
Cause
Non-compliance was mainly due to a lack of proper oversight over this requirement.
Effect
As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis.
Questioned Cost
None. Identification of a repeat finding
This is a repeat finding from the immediate previous audit. Finding 2022-001.
Recommendation
The University must ascertain that students’ documentation and other information necessary to comply with the federal funds’ enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations.
Views of responsible officials and corrective action plan
The University management agrees with this finding. Please refer to the corrective action plan on pages 59.