Finding Text
Criteria or Requirement34 CFR 685.309 states that 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 (NSLDSFAP) website.Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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. An 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 the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. (Note: The automated processes and required reporting are described in the NSLDS Enrollment Reporting Guide. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.)When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student 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; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change).Condition FoundFor 5 out of 40 enrollment status changes sampled, comparison of the institution?s records to that of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a timely basis. Therefore, EVMS did not report the status changes to NSLDS within the required timeframe of 60 days from the date they became aware of the change.Possible Cause and EffectManagement?s review over its enrollment reporting requirements for SFA was not operating as designed to ensure timely reporting of status changes. The personnel responsible for notifying the registrar of status changes, did not effectively communicate the students? status changes due to inadequate training of responsibilities. As such, certain status changes were not reported timely to NSLDS.Questioned CostsThe questioned costs associated with this finding are not determinable as the finding is not of monetary nature.Sampling ApproachThe sample was not intended to be, and was not, a statistically valid sample.Identification of Repeat FindingThis finding is not a repeat of a finding in the immediately prior year.RecommendationWe recommend that EVMS reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and controls around the timeliness of SFA program enrollment reporting requirements.Views of Responsible OfficialsEVMS agrees with the findings and the recommendation. EVMS has developed controls around thetimeliness of enrollment reporting. The instances of noncompliance were due to reliance on the newlyintegrated student information system where the system was not pulling accurate information; therefore,causing delays in reporting the most current enrollment information. As such, management hasimplemented a reconciliation control to ensure the accuracy of student enrollment information from thesystem by reviewing a weekly report of status changes and ensuring they agree to the institution?s recordsto ensure the report is complete and accurate. In addition, management has put in place a mitigatingcontrol for which Financial Services (a separate department) will also perform a monthly review of changesreported within NSLDS to ensure that the last enrollment report information is reflective of the most up todate data. This control will detect and correct any discrepancies identified as a result of the review in orderto ensure accurate reporting is performed within a timely basis of 60 days. This control activity will alsoensure any manual updates are accurately reflected in NSLDS on the next monthly report preventinginaccurate overrides. With the implementation of these two controls, the untimely enrollment reporting willbe prevented.