Finding 515770 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-18
Audit: 333609
Organization: Otis College of Art and Design (CA)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The College failed to report one student's enrollment status change to the NSLDS within the required timeframe, indicating a significant deficiency in internal controls over compliance.
  • Impacted Requirements: This affects compliance with 34 CFR section 685.309(b)(2)(i), which mandates timely reporting of enrollment changes to ensure accurate student loan eligibility and subsidy protection.
  • Recommended Follow-Up: Implement a detective control to verify student status changes against the NSLDS, and establish immediate reporting procedures for withdrawals to prevent future delays.

Finding Text

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See SFQC - Section III - Finding 2024-002 for included table) Criteria – Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that institution but has ceased to be enrolled on at least a half-time basis. Condition/Context – A sample of 25 out of a population of approximately 196 federal aid recipient students were selected from system generated reports of students who had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the 2023-2024 academic year. A comparison was made between each selected student’s National Student Loan Data System (NSLDS) enrollment detail to the student’s academic files and other institutional records to verify that the College was accurately reporting significant campus-level and program-level enrollment data within the required time frame. Of the 25 students whom had a change in address, graduated, or withdrew, 1 was not reported to the NSLDS within the required timeframe. Questioned Costs – No questioned costs were identified as part of this finding. Effect – Enrollment status is utilized by students, the U.S. Department of Education, the Direct Loan program, lenders, and other institutions to determine in‐school status. NSLDS also uses the newly submitted enrollment data to recalculate a student’s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, this significant deficiency in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit. Cause – The student status change was not timely reported due to the College not having effective internal controls established to prevent, or detect and correct, the non-compliance in a timely manner. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the College implement a detective control by which a sample of student status changes are subsequently verified within the NSLDS for accurate and timely reporting. Views of Responsible Officials and Planned Corrective Actions – Otis College of Art and Design agrees with the finding. The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto and Registrar Nicole Raef are the responsible individuals for implementation of the corrective action plan. Upon review of the finding, Financial Aid administration met with Registrar’s staff to create a new procedure whereby immediate reporting of withdrawals are made directly to NSLDS in addition to the regularly scheduled monthly reports to NSLDS through the National Student Clearinghouse (NSC). This immediate reporting should eliminate any timing issues with the monthly reports through NSC. In addition, a joint effort to streamline the routing of withdrawal forms to the appropriate departments for faster processing is underway. This reprocessing of the withdrawal forms will be implemented in the next 120 days.

Categories

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

Other Findings in this Audit

  • 515763 2024-001
    Significant Deficiency
  • 515764 2024-001
    Significant Deficiency
  • 515765 2024-001
    Significant Deficiency
  • 515766 2024-001
    Significant Deficiency
  • 515767 2024-002
    Significant Deficiency
  • 515768 2024-002
    Significant Deficiency
  • 515769 2024-002
    Significant Deficiency
  • 1092205 2024-001
    Significant Deficiency
  • 1092206 2024-001
    Significant Deficiency
  • 1092207 2024-001
    Significant Deficiency
  • 1092208 2024-001
    Significant Deficiency
  • 1092209 2024-002
    Significant Deficiency
  • 1092210 2024-002
    Significant Deficiency
  • 1092211 2024-002
    Significant Deficiency
  • 1092212 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $13.62M
84.063 Federal Pell Grant Program $2.59M
84.007 Federal Supplemental Educational Opportunity Grants $212,003
84.033 Federal Work-Study Program $166,493