Finding 518425 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-09
Audit: 336808
Organization: University of St. Thomas (TX)

AI Summary

  • Core Issue: The University failed to notify NSLDS of enrollment changes, violating federal regulations.
  • Impacted Requirements: Compliance with Special Tests and Provisions for Enrollment Reporting as per the Uniform Guidance.
  • Recommended Follow-Up: Evaluate and strengthen controls to ensure timely reporting of enrollment changes to NSLDS.

Finding Text

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Grant Program U.S. Department of Education Program Year 2023-2024 Type of Finding: Other Instance of Noncompliance and Significant Deficiency Criteria: Management is responsible for compliance with Special Tests and Provisions – Enrollment Reporting procedures in accordance with the Uniform Guidance. (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Condition: Federal regulations provide that the University is responsible for notifying the National Student Loan Data System (NSLDS) of enrollment change. NSLDS was not notified, and the University’s internal control system did not prevent or detect that the NSLDS was not notified of change. Questioned Costs: None Context: Out of a population of 661 students with enrollment changes, a sample of 25 students were selected for testing. 2 out of the 25 enrollment changes did not get reported to NSLDS. Our sampling method was not, and was not intended to be statically valid. Effect: The failure to report enrollment changes to NSLDS may result in inaccurate or delayed updates to student loan records. Cause: The University’s processes did not ensure that enrollment status changes were completed accurately and timely to NSLDS. Repeat Finding: No Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting, ensuring NSLDS receives notification of enrollment changes. Views of Responsible Officials: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Corrective Action Plan

Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that a final transmission for the term always occurs after the end date of each term. Additionally, we have identified a potential issue where NSC may fail to send graduate records to NSLDS for students who immediately re-enroll in the subsequent semester. Due to timing between the submission from NSC to NSLDS, the newer enrollment appears to be overriding the previously sent graduation record, preventing the graduation record from being sent to NSLDS. To address this, we will create a dedicated report to identify students in this situation and manually update NSLDS with the missed graduation data. Finally, there were isolated cases where a historical date adjustment was made to generate an auxiliary outcome (e.g., a grade change of Withdrawal instead of Withdrawal Failing), which made it appear as though a record change wasn't submitted in a timely manner. For these, we will discontinue this practice and employ an alternative method to derive the desired outcome (e.g., additional grade change transactions input after the withdrawal with no date adjustment). Person(s) Responsible for Implementing: Mike Acosta, Institutional Analyst, Nathan Dugat, Registrar, Lynda McKendree, Dean of Scholarships and Financial Aid Implementation Date: 11/01/2024

Categories

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

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $14.64M
84.063 Federal Pell Grant Program $7.53M
84.031 Higher Education Institutional Aid $355,227
84.007 Federal Supplemental Educational Opportunity Grants $326,754
84.033 Federal Work-Study Program $234,993
84.116 Fund for the Improvement of Postsecondary Education $208,602
47.070 Computer and Information Science and Engineering $198,799
84.120 Minority Science and Engineering Improvement $129,233
47.049 Mathematical and Physical Sciences $113,908
84.425 Education Stabilization Fund $50,096
45.310 Grants to States $507