Finding 44738 (2022-001)

- Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 39697
Auditor: Galindez LLC

AI Summary

  • Core Issue: The University failed to report student enrollment status changes accurately and on time, with 9% of cases non-compliant.
  • Impacted Requirements: Timely enrollment reporting is essential for federal aid eligibility and must occur within 30 days of status changes.
  • Recommended Follow-Up: Ensure proper oversight and training for staff on enrollment reporting, and implement procedures to meet reporting deadlines.

Finding Text

Finding No. 2022-001 - Special Tests and Provisions ? Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a 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, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. 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 Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2022. As a result of our test, we noted that for two (2) out of twenty-three (23) cases that received Student Financial Assistance funds, or 9% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations. In addition, we noted two (2) cases, or 9% of the applicable sample, for which the student?s status was incorrectly reported. We also noted two (2) cases, or 9% of the applicable sample, for which the student?s status was reported late exceeding the sixty (60) days allowed. Context Of the 148 instances of status changes, we selected twenty-five (25) students and determined that for six (6) out of twenty-three (23) cases that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2021-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.

Corrective Action Plan

The identified instances were recorded before the university put in place the controls described below. In order to assure compliance with NSLDS reporting requirements, determinations of funds earned, and timing, beginning with academic year 2022-2023 (August-2022) the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs will also attend to facilitate thediscussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent totwo consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letter to the faculty from the Office of the Dean of Academic Affairs to highlight the importance to promptly refer any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status. n addition to the above-mentioned procedures the following measures will be taken: 1. Late reporting of graduation dates in NSLDS and effective dates: a. Prior to graduation all academic program directors review the degrees to be conferred and certify candidates eligible for graduation b. The Registrar?s Office changes the status to graduate in the NSLDS Report after graduation date. c. To assure that all degrees are reported on time and accurately to the NSLDS system from now on, the Registrar?s Office, within ten days after graduation date, will process the changes in the NSLDS system. After the Registrar?s Office processes the changes in the NSLDS system, it will send to all program directors the list of all the students processed as graduated in the NSLDS system and they will be asked to double verify and attest accuracy of the lists of conferred degrees and asked to provide a certification within two days that the changes processed were accurate and that they agree with their record of students officially graduated during the last graduation date. This double certification of conferred degrees within the proposed time-frame will provide a second opportunity to add or delete any missing information within the NSLDS system increasing accuracy and timelines. d. A copy of the certification will be submitted to the Office of the Dean of Academic Affairs as evidence of the compliance with the new process established.

Categories

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

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $18.33M
84.063 Federal Pell Grant Program $432,691
93.732 Mental and Behavioral Health Education and Training Grants $327,617
93.060 Competitive Abstinence Education (cae) $270,254
84.938 Disaster Recovery Assistance for Education $184,834
84.031 Higher Education_institutional Aid $159,191
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $156,618
93.788 Opioid Str $151,151
93.866 Aging Research $116,292
93.855 Allergy, Immunology and Transplantation Research $82,898
84.425 Education Stabilization Fund $52,781
93.839 Blood Diseases and Resources Research $33,827
84.033 Federal Work-Study Program $30,975
93.424 Non-Aca/pphf?building Capacity of the Public Health System to Improve Population Health Through National Nonprofit Organizations $25,810
93.859 Biomedical Research and Research Training $22,780
84.007 Federal Supplemental Educational Opportunity Grants $12,451
93.763 Alzheimer?s Disease Initiative: Specialized Supportive Services Project (adi-Sss) Thru Prevention and Public Health Funds (pphf) $6,636
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $5,897
93.663 Extramural Research Restoration Program: Hurricanes Harvey, Maria, and Irma Non-Construction $2,496
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $1,493
93.498 Provider Relief Fund $1,236
93.279 Drug Abuse and Addiction Research Programs $600