Finding 509361 (2024-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-11-20
Audit: 329155
Organization: Southern Virginia University (VA)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University failed to report student enrollment statuses accurately and on time, affecting compliance with federal requirements.
  • Impacted Requirements: Enrollment reporting for Pell Grants and Direct Loans must be timely and accurate, including both Campus Level and Program Level data.
  • Recommended Follow-Up: Enhance internal controls and procedures for enrollment reporting to prevent future inaccuracies and ensure compliance with NSLDS requirements.

Finding Text

Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. 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. Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 5 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days. For 5 of 40 campus level records tested, the University did not notify the Department of a change in the student’s enrollment. For 25 of 40 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. See “Status of Finding” for Finding 2023-002.

Corrective Action Plan

Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. Anticipated Completion Date: Completed

Categories

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

Other Findings in this Audit

  • 509362 2024-001
    Significant Deficiency Repeat
  • 509363 2024-002
    Significant Deficiency
  • 509364 2024-002
    Significant Deficiency
  • 509365 2024-002
    Significant Deficiency
  • 509366 2024-002
    Significant Deficiency
  • 509367 2024-003
    -
  • 509368 2024-004
    -
  • 1085803 2024-001
    Significant Deficiency Repeat
  • 1085804 2024-001
    Significant Deficiency Repeat
  • 1085805 2024-002
    Significant Deficiency
  • 1085806 2024-002
    Significant Deficiency
  • 1085807 2024-002
    Significant Deficiency
  • 1085808 2024-002
    Significant Deficiency
  • 1085809 2024-003
    -
  • 1085810 2024-004
    -

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.52M
84.063 Federal Pell Grant Program $2.63M
84.007 Federal Supplemental Educational Opportunity Grants $80,500
84.033 Federal Work-Study Program $38,641