Finding Text
Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $42,889,579 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P201391, P063P211391, P063P221391, P268K201391, P268K211391, and P268K221391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers that had a reduction or increase in attendance levels at the University, we noted 4 out of 40 (10%) students whose program-level record was not updated to reflect student?s program enrollment status. Additionally, we noted 29 out of 40 (73%) students whose campuslevel record and program-level record were not updated within the required time frame, ranging from 6-40 days late. The sample was not a statistically valid sample. The University is required to accurately report significant data elements under the program level-record that the Department of Education considers high risk, including program enrollment status. The University is also required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how program-level data was being submitted to the National Student Clearinghouse (NSC), resulting in program enrollment status changes not being reported for 4 students. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations was being submitted to the NSC at least every 30 days, there was a flaw in the University?s process that caused degree confirmations submitted to the NSC to be overridden with other student enrollment information, prior to information being reported from the NSC to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date. For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required program-level data was being reported to NSLDS via NSC. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University?s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all program level detail is being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. The University's procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance.