Finding 41968 (2022-001)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-10-27
Audit: 45749
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: There were errors in reporting student enrollment statuses to NSLDS, affecting five out of 68 sampled students.
  • Impacted Requirements: Compliance with federal regulations on timely and accurate enrollment reporting is critical; errors can lead to incorrect loan repayment dates.
  • Recommended Follow-Up: Revise reporting policies to ensure accurate data entry and analyze the causes of these errors for future prevention.

Finding Text

Finding 2022-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.063 and 84.268 Federal Award Number: P063P202288, P063P212288, P063Q202288, P063Q212288, P268K212288, P268K222288 Award Year: 2021/2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria: Per 34 CFR 690.83(b)(2), 34 CFR 685.309, and the 2021 Compliance Supplement, institutions are required to report enrollment information under the Pell grant and Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by the 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. Institutions are responsible for accurately reporting the following significant data elements that the Department of Education considers high risk: Enrollment Effective Date and Enrollment Status. Further, schools are required to certify enrollment statuses every 60 days or every other month. Condition: We tested a sample of 68 students who received Title IV funds and had an enrollment status change during the year, noting 5 students with errors. Of the students with errors, two students had incorrect withdrawal status effective dates reported to NSLDS. The other three students with errors had incorrect enrollment statuses reported to NSLDS, which also resulted in reporting outside of the 60 day timely reporting window. These three students were reported as attending instead of withdrawn. Cause: Causes for the errors were varied. Due to a reporting error, one student?s withdrawal status effective date was incorrectly submitted as the end of his current term instead of the date of his official withdrawal communication. Due to timing of the NSLDS initial reporting for the term, one student?s withdrawal status effective date was incorrectly entered as the end of his previous term; the effective date should have been during the first month of the subsequent term which he attended for several days, and from which he then withdrew. Due to an error in automated enrollment status reporting package parameters, three students withdrew prior to the end of the spring semester, but their withdrawn status changes were inadvertently excluded from the automated enrollment roster reporting. Effect: Each of these five students had an incorrect data reported to NSLDS relating to their withdrawal. The result is an incorrect beginning date for their loan repayment grace periods. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 68 students who received $582,192 in Title IV Aid, out of a population of 806 students who received $9,210,850 in Title IV aid. All students in the population and sample withdrew, graduated, or had a reduction or increase in attendance levels during the year. 5 of the students had errors in reported data. Repeat Finding from Prior Year: No Recommendation: We recommend that the University revisit enrollment status change reporting policies to ensure that student changes entered into Jenzabar are appropriately included in the regularly scheduled enrollment reporting roster uploads. Further, we suggest that the University analyze the specific situations to determine how and why the errors occurred. View of Responsible Officials: Management agrees with the finding. See Corrective action plan.

Corrective Action Plan

CORRECTIVE ACTION PLAN Finding 2022-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.063 and 84.268 Finding Summary: University of Mary Hardin-Baylor (?UMHB?) had three conditions that led to NSLDS reporting discrepancies for five students. Cause 1: A system report used for NSLDS reporting incorrectly included the end of a student?s enrollment term instead of the date of official withdrawal communication. Cause 2: UMHB did not adjust the NSLDS transmittal calendar when UMHB?s academic calendar was modified for an earlier start date. Cause 3: A system report used for NSLDS reporting did not include withdrawal dates for students that had unofficially withdrawn. Responsible Individuals: Trent Bridges, Director of Data Quality & Institutional Analytics Bethany Chapman, Institutional Research Coordinator Corrective Action Plan: Related to Causes 1 and 3: UMHB will review all the coding on system reports used for NSLDS reporting to assess accuracy and completeness of the data based on any changes in business practice and make updates to system reports as necessary. UMHB will update its internal process to document any required special handling of records based on system limitations. UMHB will reassess system report and processes used for NSLDS reporting prior to the beginning of each fall and spring semester. Related to Cause 2: UMHB has adjusted its NSLDS submission schedule according to our new academic calendar with the first of term submission occurring on the census date. UMHB will establish a schedule to include more frequent submissions throughout the term. Additionally, UMHB will run a withdrawal report twice a month and manually adjust enrollment status to ensure these students are reported as withdrawn correctly to NSLDS. Anticipated Completion Date: September 15, 2022

Categories

Student Financial Aid Special Tests & Provisions Material Weakness Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 41969 2022-001
    Material Weakness
  • 41970 2022-001
    Material Weakness
  • 41971 2022-001
    Material Weakness
  • 41972 2022-001
    Material Weakness
  • 41973 2022-001
    Material Weakness
  • 618410 2022-001
    Material Weakness
  • 618411 2022-001
    Material Weakness
  • 618412 2022-001
    Material Weakness
  • 618413 2022-001
    Material Weakness
  • 618414 2022-001
    Material Weakness
  • 618415 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $37.35M
84.038 Federal Perkins Loan Program $694,739
84.425 Education Stabilization Fund $440,497
84.033 Federal Work-Study Program $306,305
84.007 Federal Supplemental Educational Opportunity Grants $246,422
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $11,316
84.063 Federal Pell Grant Program $6,525