Finding 477958 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-07-09
Audit: 314659
Organization: Regis University (CO)
Auditor: Rubinbrown

AI Summary

  • Core Issue: The University has a significant deficiency in its internal controls for timely enrollment reporting to NSLDS, failing to meet the 60-day certification requirement.
  • Impacted Requirements: Compliance with 34 CFR 682.610 and the NSLDS Enrollment Reporting Guide, which mandates accurate and timely reporting of enrollment changes.
  • Recommended Follow-Up: Revise the enrollment reporting process to ensure all changes are certified to NSC and NSLDS within the required 60 days.

Finding Text

Finding 2023-001 - Significant Deficiency: Special Tests and Provisions - Control Finding ALN 84.063 - Federal Pell Grant Program and 84.268 - Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 682.610 (and further clarified in the November 2022 National Student Loan Data System (NSLDS) Enrollment Reporting Guide), a University is required to certify changes in enrollment data for students within 60 days of the change. Universities are responsible for accurately reporting certain key information, such as the OPEID number, enrollment effective date, enrollment status, graduation status and certification date. Condition: The University recently implemented a revised process and related set of internal controls to ensure that the required enrollment information is submitted to NSLDS accurately. While the University’s standard process includes reporting changes in enrollment status every 30 days to the National Student Clearinghouse (NSC), the updated process included fixed dates for submitting degree verification status updates. Due to multiple start terms (including variable), and the ability for students to have multiple active programs, the error reports were quite large; and therefore, the University began quarterly reporting of graduated status to the National Student Clearinghouse to reduce errors despite the 60-day requirement period. Cause: The process and related internal controls surrounding enrollment reporting related to degree verification through NSC were not designed to ensure timely certification of enrollment reporting changes for graduation statuses, within the 60-day requirement period to NSLDS. Effect: The University’s controls may not prevent potential errors related to timely certification of enrollment reporting. Questioned Costs: Not applicable. Context: Our audit sample of 40 students did not indicate any instances of noncompliance related to enrollment reporting. However, our understanding of the process and internal controls deployed by the University for this compliance requirement did identify a significant deficiency in the design of the internal controls that indicates a likelihood for noncompliance with the enrollment reporting requirements is present. Recommendation: The University should revise the process and internal controls surrounding enrollment reporting to ensure that all enrollment reporting status changes are certified to NSC and thereby NSLDS within the 60-day requirement period. Views Of Responsible Officials: The University acknowledges that the enrollment report update calendar was set to only certify changes four times per year in the 2022-2023 award year.

Categories

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking Subrecipient Monitoring Internal Control / Segregation of Duties Reporting Significant Deficiency

Other Findings in this Audit

  • 477957 2023-001
    Significant Deficiency
  • 1054399 2023-001
    Significant Deficiency
  • 1054400 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $48.81M
84.063 Federal Pell Grant Program $3.35M
84.038 Federal Perkins Loan Program $1.48M
93.364 Nursing Student Loans $1.15M
84.033 Federal Work-Study Program $607,790
84.007 Federal Supplemental Educational Opportunity Grants $498,357
93.359 Nurse Education, Practice Quality and Retention Grants $466,745
93.264 Nurse Faculty Loan Program (nflp) $240,238
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $233,862
84.425 Education Stabilization Fund $98,775
93.865 Child Health and Human Development Extramural Research $28,682
12.903 Gencyber Grants Program $16,542
47.049 Mathematical and Physical Sciences $15,691
12.905 Cybersecurity Core Curriculum $6,600
47.076 Education and Human Resources $3,505