Finding 515819 (2024-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-19
Audit: 333674
Organization: Ashland University (OH)
Auditor: Schneider Downs

AI Summary

  • Core Issue: The University failed to accurately report student enrollment data to the NSLDS, as required by the U.S. Department of Education.
  • Impacted Requirements: The institution must submit enrollment reports within 30 days of receipt and notify the Secretary of any changes affecting federal loans.
  • Recommended Follow-Up: Review and improve policies for timely data submissions, and ensure ongoing training for staff involved in enrollment reporting.

Finding Text

Identification of the federal program and specific federal award: i. Assistance listing title and number: Student Financial Assistance - Cluster, Federal Pell Grant (Pell) - 84.063 ii. Federal award identification number and year: P063P210331, 2021 - 2022 Federal Award Year iii. Name of federal agency: U.S. Department of Education iv. Name of the applicable pass-through entity: Not applicable b. Criteria or specific requirement (including statutory, regulatory or other citation): An institution shall, upon receipt of an Enrollment Reporting roster file from the Secretary of the U.S. Department of Education (ED) (Secretary), complete and return that report within 30 days of receipt. Unless the institution expects to submit its next enrollment report to the Secretary within the next 60 days, the institution must notify the Secretary or the lender within 30 days if: the institution discovers that a federal loan has been made to or on behalf of a student who enrolled at that school but who has ceased to be enrolled on at least a half-time basis; the institution discovers that a federal loan has been made to or on behalf of a student who has been accepted for enrollment at that school but who failed to enroll on at least a half-time basis for the period for which the loan was intended; or the institution discovers that a student who is enrolled has changed his or her permanent address. See 34 C.F.R. § 685.309(b). c. Condition: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding its participation in the “Pell for Students Who Are Incarcerated” experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates, reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years, and update and correct errors identified. Cause: ED, as a result of the FPR and the findings contained within the Final Program Review Determination (FPRD) on September 16, 2022, required the University to update its enrollment data to correct certain errors. e. Effect or potential effect: The enrollment data for the University’s students in the NSLDS was deemed to be inaccurate by ED. f. Questioned costs: There are no questioned costs associated with this finding. g. Context: This matter arose as a result of the FPR and findings contained within the FPR and ED’s determination that data needed to be corrected. The University commenced the process to correct the data subsequent to the issuance of the FPRD and completed this process subsequent to May 31, 2023. h. Identification as a repeat finding, if applicable: This is a repeat finding of Finding 2023-001. i. Recommendation: We recommend the University review its policies and procedures to ensure that there are timely and complete submissions to the NSLDS, and that training occur for those individuals who are involved in the uploading of enrollment data to the NSLDS. j. Views of responsible officials: Management concurs with the finding. The Registrar’s Office has performed a further review of its policies and procedures to continue to ensure timely, accurate and complete submissions to the NSLDS. A how-to manual has been developed and training has occurred and regular training cadence has been developed utilizing training resources provided by associations and the U.S. Department of Education. The required corrections were completed on September 30, 2024.

Corrective Action Plan

The Registrar's Office has performed a further review of its policies and procedures to continue to ensure timely, accurate, and complete submission of enrollment records. The Registrar’s Office has updated its procedures to include response schedules with internal control mechanisms for monitoring compliance with the seven-day response requirement to the Provost’s Office and processing requests for additional assistance as necessary. The updated response schedule includes a goal to respond to error reports within four days of receipt, with final submission no later than six days following notice of the error report, unless the Provost has been notified that enrollment updates have been suspended by National Student Clearinghouse while files are being processed, in which case the Registrar’s Office will monitor and document the processing status until the suspension has been raised. Any response which will exceed six days requires written notice to the Provost’s Office with a plan to complete the required enrollment updates by 5:00pm ET on the seventh day, and any request for additional assistance or resources necessary to do so. Members of the Registrar’s Office also participated in additional training through National Student Clearinghouse with respect to enrollment reporting and error report codes related to enrollment effective dates. Training related to enrollment reporting will be scheduled at least annually through the Registrar’s Office. Finding 2022-005 of the Final Audit Determination (FAD) found that student enrollment status effective dates required further updates following the initial data corrections which were completed in September 2023. In addition to review of its policies and procedures and training, the Registrar’s Office engaged with its third-party servicer for enrollment reporting to review the data reporting systems and integration, as well as the data and information reported by the servicer to the National Student Loan Data System (NSLDS), during its response to Finding 2022-005. In response to the required action for this finding, the University requested an extension and the extension was granted to complete the required action with the U.S. Department of Education Office of Federal Student Aid (FSA). FSA requested regular status reporting and the University complied with the reporting requirement. The status reporting included updates as to the progress of the review and the University’s methods for reviewing and updating the enrollment reports so that FSA could ensure timely and accurate progress was being achieved throughout the University’s completion of the required action. The University completed the required corrections within the extension timeline of September 30, 2024.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 1092261 2024-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $20.10M
84.063 Federal Pell Grant Program $18.93M
84.007 Federal Supplemental Educational Opportunity Grants $905,415
93.264 Nurse Faculty Loan Program (nflp) $816,296
84.038 Federal Perkins Loan (fpl) - Federal Capital Contributions $455,170
84.033 Federal Work-Study Program $402,804
84.425 Elementary and Secondary School Emergency Relief Fund $345,460
84.116 Fund for the Improvement of Postsecondary Education $139,910
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $98,544
93.867 Vision Research $77,898
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $21,035
10.216 1890 Institution Capacity Building Grants $18,804
81.049 Office of Science Financial Assistance Program $15,217
59.037 Small Business Development Centers $2,591
47.074 Biological Sciences $646