Finding 42264 (2022-002)

Finding Number: 2022-002 Program Student Financial Assistance (SFA) Cluster - Various CFDA numbers Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions ? Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file E5with the default set at minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution?s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or Section III ? Federal Award Findings and Questioned Costs (continued) Finding Number: 2022-002 (continued) the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Condition We noted that for 17 students selected for testing, the University was not in compliance with the requirements as follows: Instances of Noncompliance: A ? The status change was never reported to National Student Loan Data System (NSLDS) which is the Department of Education central database for student aid. B - The status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. C- The University could not provide supporting information from the National Student Loan Data System (NSLDS) to demonstrate accurate enrollment reporting was completed. "See Schedule of Findings and Questioned Costs for chart/table". Section III ? Federal Award Findings and Questioned Costs (continued) Finding Number: 2022-002 (continued) Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. An incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Effect This condition prevents the University from reporting a student?s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 8,133 students that had a reduction or increase in attendance levels, dropped out, withdrew+E1, never attended, or requested graduation for fiscal year 2022). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2021-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management?s Response The University of Puerto Rico concurs with this finding.