Finding 391949 (2023-004)

Findings and Questioned Costs Relating to Federal Awards Current Year Finding: Number 2023-004 Federal Programs: Student Financial Assistance Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Award #’s: P268K230395, P063P220395 Federal Award Years: July 1, 2022 to June 30, 2023 Federal Agencies: U.S. Department of Education Pass-Through Entity: None Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (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 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that the Department of Education (ED) considers high risk: • OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk • OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. 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. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. For a sample of forty students who were recipients of Direct Loans or Pell Grants between July 1, 2022 and June 30, 2023 who had been identified as having withdrawn, graduated, or modified their enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in course load, the following were noted: • For one student out of forty selected for testwork, the University inaccurately reported their Campus_x0002_Level and Program-Level enrollment status as Withdrawn instead of Graduated. • For one student out of the forty selected for testwork, the University inaccurately reported their Campus-Level and Program-Level enrollment status as half time when the University’s published policies and enrollment records indicated that they are enrolled as three-quarter time. • For one student out of the forty selected for testwork, the University inaccurately reported their Campus-Level enrollment status as half time when the University’s published policies and enrollment records indicated that they are enrolled as three-quarter time. Additionally, we were not able to inspect this student’s Program-Level data from NSLDS to validate the accuracy of those significant data elements. • For one student out of the forty selected for testwork, the University inaccurately reported their Campus-Level and Program-Level enrollment status as less-than-half-time, instead of Graduated. • For two students out of the forty selected for testwork, the University inaccurately reported their Campus-Level enrollment status as less-than-half-time, instead of Graduated. Additionally, we were not able to inspect these students’ Program-Level data from NSLDS to validate the accuracy of those significant data elements. • For nine students out of forty selected for testwork, we were not able to inspect either Campus-Level or Program-Level data from NSLDS to validate the accuracy of significant data elements. Cause and Possible Asserted Effect: The University’s controls over its review of the recording and communication of these status changes does not operate consistently to and ensure that individuals’ enrollment statuses are completely and accurately communicated to NSLDS. The University has a system limitation that prevents the enrollment statuses to be reflected as three-quarter time, as well as a system limitation that prevents review of the Campus-Level or Program-Level data from NSLDS. Identification of questioned Costs: There are no questioned costs related to this finding. Sampling: The sample was not intended to be and was not a statistically valid sample. Recommendation: We recommend that the University strengthen its review of graduation and withdrawn enrollment statuses. Additionally, we recommend the University update its system configuration to add the three-quarter time enrollment status. We also recommend that the University work with the Department of Education to ensure access to NSLDS is maintained in order to review Program-Level data elements. Identification of Repeat Finding This finding is not a repeat of a finding in the immediately prior year. Views of Responsible Officials: The University agrees with this finding. The University submits its enrollment status changes through the National Student Clearinghouse system to ensure proper recording in NSLDS. The University will strengthen its controls to ensure that the Registrar Office validates the completeness and accuracy in the NSLDS system by reconciling the data per the NSLDS system to what is recorded in the University’s system for both branch locations; the main campus (003714-00) and HU Online (003714-81). Additionally, the Registrar’s Office will strengthen its monitoring controls over the transmission for both branch locations to ensure the data transmission is complete and accurate.