Finding 405970 (2023-001)

Finding 2023-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster – Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Nonmaterial Noncompliance, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes – 2022-001, 2021-001, 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (“NSLDS”). Enrollment status changes for students must 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. Enrollment information must be reported whenever a student’s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student’s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government’s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: Enrollment information was not properly submitted to NSLDS during 2023. QUESTION COSTS: None noted. CAUSE: The School did not properly implement the corrective action plan from the prior year audit until April 2024. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar’s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT’S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College submitted enrollment reports over the past year according to our approved submission schedule, but the reports were rejected due to configuration issues with our student information system (SIS). We worked diligently to resolve these issues with assistance from Anthology and the National Student Clearinghouse. All the reporting configuration issues that prevented timely and accurate reporting have been resolved and verified by the National Student Clearinghouse and on April 16, 2024, we were officially partnered with the Clearinghouse. On that date the Registrar, Financial Aid Manager, and Associate Vice President of Education attended a 2-hour training session, which covered proper reporting procedures and resolving error reports. The College has implemented a process whereby the Registrar reports graduation statuses at the conclusion of each term to the College’s SIS for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. The Registrar will create a separate report of students who have completed a program yet are continuing their education at the College. In addition, the Registrar will generate a weekly report from the College’s SIS listing the last date of attendance for drops and withdrawals, leaves of absence, and standard periods of non-enrollment and upload to the National Student Clearinghouse with subsequent transmission to NSLDS monthly. Submitting the report will be a joint venture between the Registrar, the Financial Aid Manager, and the Associate Vice President of Education. As an internal control, seven days after each scheduled submission, the Associate Vice President of Education will review the submission and any error reports and verify that the enrollment reporting for this period is complete. Enrollment reporting status will be reported as an agenda item at all bi-weekly operations meetings. To ensure timely reporting, all will receive transmission and error reports, and submission dates will be set on outlook calendars as a constant reminder.