Finding 43035 (2022-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-01-15
Audit: 44218
Organization: King University (TN)

AI Summary

  • Core Issue: The University failed to update the National Student Loan Data System (NSLDS) on student enrollment statuses within the required 60-day timeframe.
  • Impacted Requirements: This deficiency violates federal regulations under 34 CFR 685.309(b) and 34 CFR 690.83(b)(2) regarding timely reporting of enrollment changes.
  • Recommended Follow-Up: Implement a process to ensure enrollment status updates are reported to NSLDS within 60 days, and address communication gaps between departments to prevent future delays.

Finding Text

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Statement of Condition: During the 2022 audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.

Corrective Action Plan

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) ?Did not supply status updates to NSLDS in a timely manner. Name of Contact Person: The Director of Registration and Records, Whitney Cleland, and the Director of Institutional Research and Assessment, Jason Thead, are responsible for the corrective action plan for this finding. Corrective Action Plan: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. Effective Fall 2022, King University will submit enrollment data uploads to the National Student Clearinghouse at least every 30 days. The first of term submission will occur within 21 days of the start date of the term. Monthly enrollment reporting will correspond with module drop/add periods and will occur no later than 10 business days after a module drop period ends, per the Academic Calendar. Additionally, and as a part of the enrollment submission process for the National Student Clearinghouse (NSC), which provides data to NSLDS, an exception report is generated for each enrollment file prior to submission. This exception report is verified and remedied before data is submitted to NSC. Once data is submitted to NSC, an error report is generated from the NSC system. For any students who have status or level changes, the Director of Institutional Research and Assessment verifies all dates with an internal report, called the Enrollment Analysis by Course report, to ensure dates are accurately reported to the NSC. This report is also used by the Office of Financial Aid to ensure withdrawal dates are consistent. This internal report and process ensures that the dates used for all offices are the same, which remedies any communication issues between offices. Additionally, notices are sent by Financial Aid for adjustments to withdrawal dates, which are corrected in our database management system (DBMS). These additional steps allow the DBMS to accurately and collectively capture all applicable students, and the exception and error reports allow the institution to ensure the correct information is reported. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created. Anticipated Completion Date Per above, effective Fall 2022, enrollment data is now uploaded to the National Student Clearinghouse at least every 30 days. Furthermore, the missing fields in the DBMS have been remedied, and the institution is working with NSC and NSLDS to correct previously misreported records by February 2023.

Categories

Student Financial Aid Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 43034 2022-001
    Significant Deficiency
  • 43036 2022-004
    Significant Deficiency
  • 43037 2022-001
    Significant Deficiency
  • 43038 2022-002
    Significant Deficiency
  • 43039 2022-003
    Significant Deficiency
  • 619476 2022-001
    Significant Deficiency
  • 619477 2022-002
    Significant Deficiency
  • 619478 2022-004
    Significant Deficiency
  • 619479 2022-001
    Significant Deficiency
  • 619480 2022-002
    Significant Deficiency
  • 619481 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $15.48M
84.063 Federal Pell Grant Program $3.36M
84.425 Covid-19 - Education Stabilization Fund $1.86M
84.038 Federal Perkins Loan Program $761,213
84.007 Federal Supplemental Educational Opportunity Grants $146,493
84.033 Federal Work-Study Program $119,414