Finding 516509 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-20
Audit: 334419
Organization: Berklee College of Music, Inc. (MA)
Auditor: Kpmg

AI Summary

  • Core Issue: Two students had inaccurate program-level enrollment data reported to NSLDS, specifically regarding their Published Program Lengths.
  • Impacted Requirements: Institutions must ensure accurate and timely reporting of enrollment information to maintain compliance with federal regulations and internal controls.
  • Recommended Follow-Up: The College should enhance its enrollment reporting processes and implement reconciliations between its records and NSC data to ensure accuracy before submission.

Finding Text

Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. 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 certify 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 (NSDLSFAP) website. 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. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Of the 40 students with enrollment changes that we selected for testwork, KPMG identified 2 students whose program level enrollment data elements were not accurately transmitted to NSLDS. Specifically, KPMG identified that 2 students’ Published Program Lengths, as reported to NSLDS, did not agree to the College’s records. The exceptions described above did not result in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. Cause The condition resulted from the College’s internal control processes not operating consistently to ensure that all changes in enrollment information at both a campus level and program level were accurately reported to NSLDS. Specifically, the College’s control of reviewing the key enrollment reporting data elements for accuracy was not operating at a level of precision that would cover all key data elements. Possible Asserted Effect Inaccurate submission of student enrollment status information and related program information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to enrollment reporting to ensure that all status change key data elements that are reported to NSLDS agree to the College’s records. Views of Responsible Officials Management concurs with the recommendations provided. The Registrar’s Office will implement a reconciliation of the Student Enrollment Information system and data provided to NSC (the National Student Clearinghouse). The reconciliations will be reviewed by the Associate Registrar and confirmed by the Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any discrepancies will be sent to NSC immediately informing them of any necessary corrections. Estimated Date of Completion: March 31, 2025

Corrective Action Plan

Responsible Individual: Joan Romano, Registrar Contact Information: jromano2@berklee.edu, 617-747-2475 Corrective Actions: Management concurs with the recommendations provided. The Registrar’s Office will implement a reconciliation of the Ellucian Colleague Enrollment Information and data provided to NSC (the National Student Clearinghouse). The reconciliations will be reviewed by Ari Kaufman, Associate Registrar, and confirmed by Joan Romano, Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any discrepancies will be sent to NSC immediately informing them of any necessary corrections. Estimated Date of Completion: March 31, 2025 Status of Completion: In Process

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 516508 2024-001
    Material Weakness
  • 516510 2024-002
    Significant Deficiency
  • 1092950 2024-001
    Material Weakness
  • 1092951 2024-002
    Significant Deficiency
  • 1092952 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $50.05M
84.063 Federal Pell Grant Program $6.77M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.40M
84.038 Federal Perkins Student Loans $982,059
84.007 Federal Supplemental Educational Opportunity Grants $954,175
84.425E Education Stabilization Fund $727,127
83.033 Federal Work-Study Program $355,287