Finding 513661 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-09

AI Summary

  • Core Issue: The University failed to report a student's enrollment status change to the NSLDS within the required timeframe, leading to inaccurate data.
  • Impacted Requirements: Compliance with 34 CFR section 685.309(b)(2) regarding timely updates to student enrollment information is essential for federal aid management.
  • Recommended Follow-Up: Implement additional monitoring procedures to regularly verify the accuracy of enrollment data reported to NSLDS.

Finding Text

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance (See table in "Schedule of Findings and Questioned Costs.") Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: 1. A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or 2. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – From a system generated population of 658 students who received federal aid and either graduated, withdrew, changed their permanent address, or dropped during the year ended June 30, 2024, we selected a sample of 60 students. We believe this to be a representative sample of the population. The enrollment information and withdrawal or graduation date per the University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 60 students who graduated, had an address change, or withdrew, one was not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS. Questioned costs: No questioned costs were identified as part of this finding. Cause – The University’s controls did not capture student status change timely. Effect – The NSLDS database did not include all accurate information in the timeframe required by ED. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine inschool status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding – This is not a repeat finding. Recommendation: We recommend the University develop additional procedures to monitor the accuracy of information reported to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to correct information directly within NSLDS at any time. Views of responsible officials: Management agrees with the finding. A corrective action plan has been created by management and is included in the following section.

Corrective Action Plan

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonstandard. Non-standard summer term students are not reported to NSC over summer if they are not enrolled. Since this student was in a year-round program, the student should have been reported with summer as a standard term. Based on Vanguard’s NSC transmission schedule, had this student’s NSC Branch been classified correctly, the student would have been in a NSC transmission standard term data file and reported within 30 days of the enrollment adjustment. Annually, the Registrar’s Office will review all programs to ensure that year-round program students are reported to NSC with summer as a standard term. The assistant registrar who is responsible for both NSC reporting and updating program degree audits will manage this process with the dean of academic records oversight. The Registrar’s Office will create a column in the annual degree audit log that indicates standard/non-standard classification has been properly determined and set up correctly in the student information system for accurate reporting to NSC. A sample set of students within each NSC transmission will be checked following transmission in NSC by the Registrar’s Office and NSLDS by the Financial Aid Office to ensure that enrollment status is accurate. Name of Contact Person: Julie Cowen, Dean of Academic Records, 714-662-5204 Projected Completion Date: Program review for standard/non-standard classification for 2024-25 was completed on October 28, 2024 and will be completed annually in March-April beginning in 2025.

Categories

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

Other Findings in this Audit

  • 513656 2024-001
    Significant Deficiency
  • 513657 2024-001
    Significant Deficiency
  • 513658 2024-001
    Significant Deficiency
  • 513659 2024-001
    Significant Deficiency
  • 513660 2024-001
    Significant Deficiency
  • 1090098 2024-001
    Significant Deficiency
  • 1090099 2024-001
    Significant Deficiency
  • 1090100 2024-001
    Significant Deficiency
  • 1090101 2024-001
    Significant Deficiency
  • 1090102 2024-001
    Significant Deficiency
  • 1090103 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $13.91M
84.063 Federal Pell Grant Program $4.98M
84.038 Federal Perkins Loans, Outstanding at Beginning of Year $987,243
84.031 Higher Education Institutional Aid $454,551
84.033 Federal Work-Study Program $286,990
84.007 Federal Supplemental Educational Opportunity Grants $205,279
84.425 Higher Education Emergency Relief Program Institutional Aid Portion $36,179