Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Assistance Listing Number: 84.063, 84.268
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610).
Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
• In our sample of 40 students tested, 1 student was not reported to the NSLDS.
• In our sample of 40 students tested, 1 student was not reported timely within the 30 or 60 day timeframe.
• In our sample of 40 students tested, 1 student did not have the correct enrollment effective date in the NSLDS at the program level.
Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University’s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2022-002.
Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.