Finding 503116 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-10-17
Audit: 325123
Organization: Saint Martin's University (WA)
Auditor: Moss Adams

AI Summary

  • Core Issue: The University failed to report enrollment changes for 22 out of 40 sampled students to the NSLDS within the required 60 days.
  • Impacted Requirements: This deficiency violates Uniform Guidance and 34 CFR section 685.309, which mandate timely and accurate reporting of student enrollment status.
  • Recommended Follow-Up: Enhance training for staff on reporting requirements and review internal controls to ensure compliance with NSLDS reporting timelines.

Finding Text

Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P230416, P268K240416 Award Year: 2023-24 Criteria: Uniform Guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to the National Student Loan Data System (NSLDS) within at least 60 days of when the student attendance change occurs. It is the University's responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR section 685.309. Condition/context: A sample of 40 students who were borrowers of Federal Direct student loans or recipients of Pell grants and had withdrawn or graduated from the University during the 2023-2024 fiscal year were selected. The enrollment information and withdrawal or graduation date per the University's records was compared to the information reported to the NSLDS. We noted that of the 40 students sampled, 19 students who had graduated and 3 students who had withdrawn from the University were not properly reported to NSLDS within the 60 day requirement. Our sample was not, and was not intended to be, statistically valid. Questioned costs: None Cause/effect: This occurred as a result of lack of well-documented controls over timely reporting to NSLDS. This resulted in late reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding: No Recommendation: We recommend the University further educate and train those involved in the reporting of enrollment status changes to the NSLDS. We also recommend the University review their documented policies and procedures and ensure controls exist and are well documented in order to ensure enrollment data is reported timely and accurately to NSLDS. Views of responsible officials and planned corrective actions: Saint Martin’s University management agrees with the finding. The Director of Financial Aid will continue education on enrollment reporting requirements. The Director and the Registrar will continue to work together on enrollment reporting requirements. The Director of Financial Aid will now report withdrawals due to return to title IV, as well as conferrals, to the National Student Loan Data System directly once the University receives notice of either withdrawal or completion of a degree. Weekly, withdrawals for return to title IV are monitored and reported and now student financial aid will report directly to NSLDS to avoid any lag time in relying on reporting to the Clearinghouse. At the end of each term, after the Registrar has conferred degrees, student financial aid will also acquire the list of students who have graduated and report their graduation status to NSLDS.

Corrective Action Plan

Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance - Federal Assistance Listing Number 84.063, 84.268 Recommendation: The auditors recommend the University further educate and train those involved in the reporting of enrollment status changes to the NSLDS. The auditors also recommend the University review our documented policies and procedures and ensure controls exist and are well documented in order to ensure enrollment data is reported timely and accurately to NSLDS. Action taken: The Director of Financial Aid will continue education on enrollment reporting requirements. The Director and the Registrar will continue to work together on enrollment reporting requirements. The Director of Financial Aid will now report withdrawals due to R2T4, as well as conferrals, to the National Student Loan Data System directly once the University receives notice of either withdrawal or completion of a degree. Weekly, withdrawals for R2T4 are monitored and reported and now SFA will report directly to NSLDS to avoid any lag time in relying on reporting to the Clearinghouse. At the end of each term, after the Registrar has conferred degrees, SFA will also acquire the list of students who have graduated and report their graduation status to NSLDS. Name of Responsible Party: Erin Schaffer Anticipated completion date: 9/30/2024

Categories

Student Financial Aid Special Tests & Provisions Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 503110 2024-001
    Significant Deficiency Repeat
  • 503111 2024-001
    Significant Deficiency Repeat
  • 503112 2024-001
    Significant Deficiency Repeat
  • 503113 2024-001
    Significant Deficiency Repeat
  • 503114 2024-001
    Significant Deficiency Repeat
  • 503115 2024-001
    Significant Deficiency Repeat
  • 503117 2024-002
    Significant Deficiency
  • 1079552 2024-001
    Significant Deficiency Repeat
  • 1079553 2024-001
    Significant Deficiency Repeat
  • 1079554 2024-001
    Significant Deficiency Repeat
  • 1079555 2024-001
    Significant Deficiency Repeat
  • 1079556 2024-001
    Significant Deficiency Repeat
  • 1079557 2024-001
    Significant Deficiency Repeat
  • 1079558 2024-002
    Significant Deficiency
  • 1079559 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $8.42M
84.063 Federal Pell Grant Program $2.96M
59.059 Congressional Grants $1.00M
93.178 Nursing Workforce Diversity $566,577
84.031 Higher Education Institutional Aid $525,999
84.033 Federal Work-Study Program $295,314
84.007 Federal Supplemental Educational Opportunity Grants $186,344
84.116 Fund for the Improvement of Postsecondary Education $132,839
84.038 Federal Perkins Loan Program $41,876
47.049 Mathematical and Physical Sciences $27,748
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $11,316
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $9,161
47.074 Biological Sciences $5,272
93.732 Mental and Behavioral Health Education and Training Grants $2,446