Finding 418207 (2022-010)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-06-11
Audit: 312179
Organization: Heritage University (WA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The University failed to report student attendance changes to NSLDS accurately and within the required 60-day timeframe.
  • Impacted Requirements: Compliance with 34 CFR § 685.309 and internal controls for reporting significant data elements, including student status changes.
  • Recommended Follow-Up: Enhance policies for timely reporting and establish a formal monitoring system to ensure accurate submissions to NSLDS.

Finding Text

Criteria: The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University?s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR ? 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus- Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date.Condition/context: We selected a sample of 28 students out of a population of 266 who had received Federal aid and had withdrawn or graduated from the University during the 2021-2022 fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University?s records. We noted exceptions with nine out of the 28 students tested. For two students their status change was not properly reported at the campus-level record. One student?s campus-level and program-level record was not correct. Six students were not reported to NSLDS within the 60-day requirement.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: This occurred because of lack of controls and oversight of the process. This resulted in late and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status.Repeat finding: NoRecommendation: We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.Views of responsible officials and planned corrective actions: Heritage University will adhere to and improve the current standards to guarantee that all student status changes are promptly identified and submitted accurately within the appropriate time period. In order to internally audit the National Student Clearinghouse submissions, the University will set up a formal internal monitoring system whereby a designated person with access to NSLDS periodically monitors the status updates on NSLDS.

Corrective Action Plan

Recommendation: The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. They also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.Planned Corrective Action: Heritage University will adhere to and improve the current standards to guarantee that all student status changes are promptly identified and submitted accurately within the appropriate time period. In order to internally audit the National Student Clearinghouse submissions, the University will set up a formal internal monitoring system whereby a designated person with access to NSLDS periodically monitors the status updates on NSLDS.Name of Responsible Party:1. Dianne Fernandez, Director of Financial Aid2. Mary Neal, Registrar3. Thomas Richter, VP of Administration/CFOAnticipated Completion Date: June 30, 2023

Categories

Student Financial Aid Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 418206 2022-009
    Significant Deficiency
  • 418208 2022-009
    Significant Deficiency
  • 418209 2022-010
    Significant Deficiency
  • 418210 2022-009
    Significant Deficiency
  • 418211 2022-002
    Material Weakness Repeat
  • 418212 2022-006
    Significant Deficiency
  • 418213 2022-007
    Material Weakness
  • 418214 2022-002
    Material Weakness Repeat
  • 418215 2022-002
    Material Weakness Repeat
  • 418216 2022-003
    Significant Deficiency Repeat
  • 418217 2022-006
    Significant Deficiency
  • 418218 2022-006
    Significant Deficiency
  • 418219 2022-007
    Material Weakness
  • 418220 2022-007
    Material Weakness
  • 418221 2022-008
    Significant Deficiency
  • 418222 2022-004
    Significant Deficiency Repeat
  • 418223 2022-005
    Material Weakness Repeat
  • 418224 2022-005
    Material Weakness Repeat
  • 418225 2022-002
    Material Weakness Repeat
  • 418226 2022-002
    Material Weakness Repeat
  • 418227 2022-002
    Material Weakness Repeat
  • 418228 2022-002
    Material Weakness Repeat
  • 418229 2022-003
    Significant Deficiency Repeat
  • 418230 2022-002
    Material Weakness Repeat
  • 418231 2022-002
    Material Weakness Repeat
  • 994648 2022-009
    Significant Deficiency
  • 994649 2022-010
    Significant Deficiency
  • 994650 2022-009
    Significant Deficiency
  • 994651 2022-010
    Significant Deficiency
  • 994652 2022-009
    Significant Deficiency
  • 994653 2022-002
    Material Weakness Repeat
  • 994654 2022-006
    Significant Deficiency
  • 994655 2022-007
    Material Weakness
  • 994656 2022-002
    Material Weakness Repeat
  • 994657 2022-002
    Material Weakness Repeat
  • 994658 2022-003
    Significant Deficiency Repeat
  • 994659 2022-006
    Significant Deficiency
  • 994660 2022-006
    Significant Deficiency
  • 994661 2022-007
    Material Weakness
  • 994662 2022-007
    Material Weakness
  • 994663 2022-008
    Significant Deficiency
  • 994664 2022-004
    Significant Deficiency Repeat
  • 994665 2022-005
    Material Weakness Repeat
  • 994666 2022-005
    Material Weakness Repeat
  • 994667 2022-002
    Material Weakness Repeat
  • 994668 2022-002
    Material Weakness Repeat
  • 994669 2022-002
    Material Weakness Repeat
  • 994670 2022-002
    Material Weakness Repeat
  • 994671 2022-003
    Significant Deficiency Repeat
  • 994672 2022-002
    Material Weakness Repeat
  • 994673 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $2.67M
84.268 Federal Direct Student Loans $2.60M
84.141 Migrant Education_high School Equivalency Program $497,387
84.149 Migrant Education_college Assistance Migrant Program $471,081
84.042 Trio_student Support Services $282,228
84.031 Higher Education_institutional Aid $236,724
84.217 Trio_mcnair Post-Baccalaureate Achievement $234,353
93.011 National Organizations of State and Local Officials $180,020
84.007 Federal Supplemental Educational Opportunity Grants $170,371
93.732 Mental and Behavioral Health Education and Training Grants $104,094
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $84,870
47.074 Biological Sciences $66,342
84.033 Federal Work-Study Program $54,613
10.558 Child and Adult Care Food Program $26,973
43.008 Education $20,649
47.075 Social, Behavioral, and Economic Sciences $12,634
45.164 Promotion of the Humanities_public Programs $9,439
45.310 Grants to States $6,946
45.129 Promotion of the Humanities_federal/state Partnership $6,447
10.310 Agriculture and Food Research Initiative (afri) $6,425
47.076 Education and Human Resources $4,118
84.425 Education Stabilization Fund $2,804
84.038 Federal Perkins Loan Program $2,285