Finding 503949 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-10-28
Audit: 326226
Organization: Drake University (IA)

AI Summary

  • Core Issue: The University failed to report changes in student enrollment status to NSLDS on time, violating federal regulations.
  • Impacted Requirements: Compliance with 34 CFR 685.309(b) regarding timely reporting of enrollment status changes within 30 days.
  • Recommended Follow-Up: The University should review and improve its reporting procedures to ensure timely updates to NSLDS for all student status changes.

Finding Text

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2023 to June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Other matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 3 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None reported. Context: During our testing, it was noted the University identified the status changes outside of their regular enrollment reporting schedule, so the reporting to NSLDS was not done timely. Cause: For 2 of the 3 students, they were enrolled in modules, and they successfully completed module one and withdrew from future modules prior to them starting. Financial Aid correctly identified these students as Title IV withdrawals and completed the R2T4 process, but the student was not reported as a withdrawal in enrollment reporting to NSLDS. For 1 of the 3 students, the student's graduation status was reported one day late. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid maintains a log of all Title IV withdrawals, and going forward it will provide access to this log to the Registrar’s Office and will notify the Associate Registrar each time a student is determined to be withdrawn for R2T4 purposes. This will ensure that the Financial Aid Office and the Registrar’s Office are aligned with regard to a student’s Title IV enrollment status. This will be particularly helpful to ensure compliance for students enrolled in modules, where a student could be considered withdrawn for a semester even if their transcript shows that credit was earned for all of their officially attempted credits. This compliance issue was discovered and remediated by Drake prior to the audit as part of our own internal review process. Upon each submission of the graduation data file to the National Student Clearinghouse, the Registrar’s Office will double-check the count of awarded degrees that appear on the submission file and compare it to the number of awarded degrees as reported by Drake’s student information system. Additionally, shortly after each file is submitted to the NSC, the Registrar’s Office will cross-check a sample of JD graduates against both the NSC database and the NSLDS database to ensure that the graduation status for graduates of the JD program is being accepted and processed by the NSC as expected, and that they are in turn properly reported to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Kevin Moenkhaus, Associate Registrar and Brandi Miller, Assistant Director of Financial Aid. Planned completion date for corrective action plan: September 1, 2024.

Categories

Student Financial Aid Internal Control / Segregation of Duties Reporting Significant Deficiency

Other Findings in this Audit

  • 503950 2024-001
    Significant Deficiency
  • 503951 2024-001
    Significant Deficiency
  • 503952 2024-001
    Significant Deficiency
  • 503953 2024-001
    Significant Deficiency
  • 503954 2024-001
    Significant Deficiency
  • 503955 2024-001
    Significant Deficiency
  • 1080391 2024-001
    Significant Deficiency
  • 1080392 2024-001
    Significant Deficiency
  • 1080393 2024-001
    Significant Deficiency
  • 1080394 2024-001
    Significant Deficiency
  • 1080395 2024-001
    Significant Deficiency
  • 1080396 2024-001
    Significant Deficiency
  • 1080397 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $39.41M
93.600 Head Start $12.12M
84.063 Federal Pell Grant Program $3.53M
84.038 Federal Perkins Loan Program $3.11M
84.007 Federal Supplemental Educational Opportunity Grants $753,550
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students $751,960
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $537,735
84.033 Federal Work-Study Program $389,453
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $385,578
93.211 Rural Telemedicine Grants $343,483
10.558 Child and Adult Care Food Program $304,764
93.576 Refugee and Entrant Assistance Discretionary Grants $277,447
84.129 Rehabilitation Long-Term Training $210,951
47.076 Stem Education (formerly Education and Human Resources) $180,500
47.049 Mathematical and Physical Sciences $167,657
47.074 Biological Sciences $68,638
95.006 Model Acts Program $49,355
10.310 Agriculture and Food Research Initiative (afri) $48,927
81.049 Office of Science Financial Assistance Program $23,562
43.008 Office of Stem Engagement (ostem) $20,250
45.024 Promotion of the Arts Grants to Organizations and Individuals $16,823
59.077 Community Navigator Pilot Program $13,356
12.431 Basic Scientific Research $11,055
45.149 Promotion of the Humanities Division of Preservation and Access $10,000
47.070 Computer and Information Science and Engineering $4,764
19.009 Academic Exchange Programs - Undergraduate Programs $1,777
12.630 Basic, Applied, and Advanced Research in Science and Engineering $1,674