Finding 391385 (2023-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-04-01
Audit: 301916
Organization: Bethany Lutheran College, Inc. (MN)

AI Summary

  • Core Issue: The College failed to report changes in student enrollment status to NSLDS within the required timeframes.
  • Impacted Requirements: Compliance with 34 CFR 685.309, which mandates timely reporting and accurate effective dates for enrollment status changes.
  • Recommended Follow-Up: The College should enhance its reporting procedures to ensure timely and accurate updates to NSLDS as per federal regulations.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work-Study Program 84.038 – Federal Perkins Loan Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 out of the 9 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: N/A Context: Updates to NSLDS were not completed in a timely manner. Cause: The College did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Auditors’ Recommendation We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely 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: Issue: Taylor Theiste began official withdrawal process on 1/31/23. This date was used in Return of Title IV calculations, and entered into PowerFAIDS system. Student was asked to unenroll from the courses by the Registrar, which she did, but not until 2 days later. Resolution: Jeff Younge (Director of Financial Aid) met with Sergio Salgado (Registrar) and Lisa Shubert (Manager of Administrative Computing and Institutional Reporting) on 11/29/23. Going forward, when student indicates intent to withdraw, Registrar will unenroll the student from courses using the withdrawal date used for Title IV purposes. This will ensure that the correct date is reported to Clearinghouse, and then to NSLDS. Issue: Ben Draper began official withdrawal process on 1/20/23. Since this was the 10th day of class, he was not included in the Census Report that was run at the end of the day (although correct date was used for Return of Title IV calculations, and transcript shows Ws). Consequently, he was treated for reporting purposes as if he did not return for spring semester, and withdrawal date sent to Clearinghouse, and then on to NSLDS, reverted to last day of the previous fall semester, which was 12/15/22. Resolution: On December 20, 2023, meeting was held in Luther Hall that included the following: (Stacey Dawley, Jeff Lemke, Jason Lowrey, Ted Manthe, Daniel Mundahl, Sergio Salgado, Lisa Shubert, Renee Tatge, Estelle Vlieger, Jeff Younge) Proposal was made (and accepted by this group, and later the President) that stated the following: 1. Add/Drop period is day 1-5 of fall and spring semester. During this time, classes can be added, and dropped courses disappear from student schedule/transcript, as if student did not begin the class. Courses withdrawn from after 5th day result in a grade on the transcript (W, WP/WF, or F, depending on the timing of the withdrawal). This is the current policy, not a proposed change. 2. Change wording of refund policy, so that instead of Week 1, Week 2, Week 3...it is worded as Day 1-5, Day 6-10, Day 11-15... (This solves the issue of 1st week being only 4 days in the fall, but 5 days in the spring, and the day after Labor Day being the 10th day of class, but 3rd week of the semester). 3. Change Census report figures from being (10th day) to (end of 5th day). That does not mean census report is available on the 5th day, but just that the information is “locked” as of that day for reporting purposes. Name of the contact person responsible for corrective action: Jeff Younge, Director of Financial Aid Planned completion date for corrective action plan: 3/26/2024

Categories

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

Other Findings in this Audit

  • 391386 2023-002
    Significant Deficiency
  • 391387 2023-002
    Significant Deficiency
  • 391388 2023-002
    Significant Deficiency
  • 391389 2023-002
    Significant Deficiency
  • 391390 2023-003
    Significant Deficiency
  • 391391 2023-003
    Significant Deficiency
  • 391392 2023-003
    Significant Deficiency
  • 391393 2023-003
    Significant Deficiency
  • 391394 2023-003
    Significant Deficiency
  • 391395 2023-004
    Significant Deficiency
  • 391396 2023-004
    Significant Deficiency
  • 391397 2023-004
    Significant Deficiency
  • 391398 2023-005
    Significant Deficiency
  • 391399 2023-005
    Significant Deficiency
  • 391400 2023-005
    Significant Deficiency
  • 391401 2023-005
    Significant Deficiency
  • 391402 2023-005
    Significant Deficiency
  • 967827 2023-002
    Significant Deficiency
  • 967828 2023-002
    Significant Deficiency
  • 967829 2023-002
    Significant Deficiency
  • 967830 2023-002
    Significant Deficiency
  • 967831 2023-002
    Significant Deficiency
  • 967832 2023-003
    Significant Deficiency
  • 967833 2023-003
    Significant Deficiency
  • 967834 2023-003
    Significant Deficiency
  • 967835 2023-003
    Significant Deficiency
  • 967836 2023-003
    Significant Deficiency
  • 967837 2023-004
    Significant Deficiency
  • 967838 2023-004
    Significant Deficiency
  • 967839 2023-004
    Significant Deficiency
  • 967840 2023-005
    Significant Deficiency
  • 967841 2023-005
    Significant Deficiency
  • 967842 2023-005
    Significant Deficiency
  • 967843 2023-005
    Significant Deficiency
  • 967844 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.50M
84.063 Federal Pell Grant Program $811,317
84.038 Federal Perkins Loan Program $164,622
84.033 Federal Work-Study Program $36,806
84.007 Federal Supplemental Educational Opportunity Grants $32,667