Finding 2022-001 Significant Deficiency and Noncompliance: Special Tests and Provision ? Enrollment Reporting Federal Agency U.S. Department of Education Federal Program and Award Number Student Financial Assistance Cluster: ? Federal Direct Student Loans (ALN 84.268) ? P268K221224 ? Federal Pell Grant Program (ALN 84.063) ? P063P211224 Federal Award Year July 1, 2021 to June 30, 2022 Criteria Under the Federal Pell Grant Program and U.S. Department of Education (ED) loan programs, institutions are required to report student 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 website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: ? Office of Postsecondary Education Identifier (?OPEID?); ? Enrollment status; ? Enrollment effective date; 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; ? Classification of Instructional Program (?CIP?) code; ? CIP year; ? Credential level ? Published program length measurement; ? Published program length; ? Program begin date; ? Program enrollment status; and ? Program enrollment effective date. Published Program Length should be reported based on the definition of ?normal time? to completion in the regulations at 34 CFR 668.41(a), as follows: ? If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. Note: For gainful employment programs, the school must have published the program?s length in weeks, months, or years on the school?s website. ? If the school has not published a program length and the program is an associate or bachelor?s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. ? For all other programs for which the school has not published a program length, the program length is based on the school?s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. The program enrollment effective date is the date that the enrollment status as of the reporting date reported for the program was first effective. Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition and Context From a sample of 40 students tested, we identified the following: 1. For 40 students, the published program lengths that were reported on the students' NSLDS Program Level records did not conform with the reporting requirements described in the NSLDS Enrollment Reporting Guide. a) For those students who were enrolled in a four-year bachelor's program, which represented 23 of 40 such students, the University reported a 48-month program length on the students? NSLDS Program Level records instead of a four-year length as described in the NSLDS Enrollment Reporting Guide (since the University does not post the program lengths for bachelor's degree programs). b) For those students who were enrolled in a graduate or professional studies program, which represented 17 of 40 such students, the University reported program lengths in months on the students? NSLDS Program Level records instead of program lengths in years as posted on the University?s website for the respective program. As a result of the University reporting such program lengths in months instead of years and reporting the incorrect ?Weeks in Title IV Academic Year? values in the NSLDS Program Level records, the published program lengths in years that were calculated in the NSLDS system were longer than the programs? standard lengths in years (i.e., for bachelor?s programs, four years; for graduate or professional studies programs, the program?s lengths in years as posted on the respective program?s website) (for instance, the NSLDS Program Level records for the 23 students who were enrolled in a four-year bachelor?s program showed a published program length in years of 6.857 years instead of four years). 2. For two students, while the University correctly reported the Graduated status effective date on these students' NSLDS Campus Level records, the Graduated status effective date on these students' NSLDS Program Level records did not agree to the University's records for the last day of the last academic semester attended by the students prior to the completion of the academic program. 3. For one student, the program begin date that was reported on the student's NSLDS Program Level record did not reflect the correct program begin date for the academic program in which the student was enrolled. Cause and Effect 1. These instances of noncompliance were caused by human error. Published program lengths were posted based on the program lengths in calendar years instead of academic years. These errors resulted in longer published program lengths in years being calculated in the NSLDS enrollment records, which impacts students? Maximum Eligibility Periods relating to Direct Subsidized Loans. 2. These instances of noncompliance were caused by human error when inputting these students? effective dates in their NSLDS Program Level records, which may have resulted in the early conversion of such students? outstanding Federal loans to repayment status. 3. This instance of noncompliance was caused by human error. This student?s program begin date was incorrectly updated to reflect the first day of the last semester in the program rather than the first day of the first semester of the program in which the student was enrolled, which may affect the calculation of the accrued interest relating to the student?s outstanding Federal loans. Questioned Costs No questioned costs were identified with respect to this finding. Statistically Valid Sample No and it was not intended to be. Repeat Finding Not a repeat finding. Recommendation The University should implement procedures to ensure that students? published program lengths, program begin dates, and program enrollment effective dates are reported to the NSLDS accurately and in accordance with the NSLDS Enrollment Guide. Views of Responsible Officials The University acknowledges the finding and has fully implemented a corrective action plan to address the recommendations.