FAC Explorer

Finding 522295 (2024-005)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-06
Audit: 341568
Organization: Commonspirit Health (IL)
Auditor: Ernst & Young LLP

AI Summary

  • Core Issue: Good Samaritan College of Nursing & Health Science lacks effective internal controls over enrollment reporting, leading to inaccurate and untimely submissions to the NSLDS.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and timely reporting of high-risk enrollment data elements is not being met, affecting student eligibility for financial aid.
  • Recommended Follow-Up: The college should enhance internal controls and refine processes to ensure accurate and timely enrollment reporting, addressing this repeat finding effectively.

Finding Text

Finding 2024-005 - Special Tests and Provisions - Enrollment Reporting Identification of the federal program: U.S. Department of Education Office of Federal Student Aid Student Financial Assistance Cluster Assistance Listing No. 84.063 Federal Pell Grant Program Assistance Listing No. 84.268 Federal Direct Student Loans Good Samaritan College of Nursing & Health Science Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) 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 statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be compliance with guidance in “Standards for Internal Control the Federal Government” issued by the Comptroller General the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Institutions are responsible for accurately reporting to the National Student Loan Data System (NSLDS) the following significant data elements under the Campus-Level Record and Program-Level Record that Department of Education (ED) considers high risk. ED considers the following Campus-Level data elements to be high risk: 1. Office of Postsecondary Education Identification (OPEID) Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date ED considers the following Program-Level Record data elements to be high risk: 1. OPEID Number 2. CIP Code 3. CIP Year 4. Credential Level 5. Published Program Length Measurement 6. Published Program Length 7. Program Begin Date 8. Program Enrollment Status 9. Program Enrollment Effective Date When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. Condition: Good Samaritan College of Nursing & Health Science did not have effective internal controls over enrollment reporting. Student enrollment information, including enrollment status changes and campus level and program level information, was not reported accurately and/or timely to the NSLDS for certain students. Cause: Good Samaritan College of Nursing & Health Science has been developing and implementing internal controls in response to the prior year finding over enrollment reporting; however, ineffective internal control led to untimely reporting and inaccurate data reported for certain students. Additionally, in the current year, a different matter was noted in that the third-party system that is used to generate reports to validate status changes was not accurate, resulting in certain enrollment status changes not being submitted to NSLDS timely. Effect or potential effect: Lack of internal controls over timely and accurate enrollment reporting resulted in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is important for effective management of the programs. Questioned costs: None. Context: EY selected 61 students from a population of 121 students receiving Pell and Direct Student Loans to test whether the required student enrollment information was accurately and timely reported to NSLDS. For the 61 students selected for testing, we tested 16 attributes for each student, for a total of 976 attributes. Of the 61 students selected, enrollment status was not reported timely, within 60 days, for 4 students receiving direct loans, with reporting to NSLDS ranging from 73 to 187 days. Additionally, of the 61 students selected, for 2 students receiving a direct loan, the correct enrollment status of withdrawn was never reported to NSLDS. As a result of the enrollment status for 6 students being reported late or inaccurately, we noted Campus-Level information was inaccurate in 10 instances for 3 data elements and Program-Level information was inaccurate in 4 instances for 2 data elements. In addition, of the 61 students selected, the program begin date was inaccurately reported for 2 students. Good Samaritan College of Nursing & Health Science has SFA Cluster expenditures of approximately $5.7 million, which makes up 95% of total SFA Cluster expenditures of approximately $6.0 million. Identification as a repeat finding, if applicable: This is a repeat finding for Good Samaritan College of Nursing & Health Science – Findings 2023-010, 2022-005, and 2021-006. An additional internal control matter related to enrollment status is reported in the current year and is a different matter from that reported in the prior years. Recommendation: Good Samaritan College of Nursing & Health Science should refine processes and develop internal controls over enrollment reporting requirements to ensure information used to determine status changes is complete and accurate and that changes in enrollment status are reported timely. Views of responsible officials: Management at Good Samaritan College of Nursing & Health Science agrees with the finding and will work with the student financial aid vendor to ensure all status changes are appropriately captured.

Corrective Action Plan

REFERENCE: 2024-005 – Special Tests and Provision – Enrollment Reporting Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science Finding: Good Samaritan College of Nursing & Health Science did not have internal controls over enrollment reporting. Student enrollment information, including enrollment status changes and campus level and program level information, was not reported accurately and/or timely to the NSLDS for certain students. Corrective Action Plan: Beginning Spring of 2024, Good Samaritan College changed their reporting cycle to include five submissions per semester. This change was encouraged as a best practice from the American Association of Collegiate Registrars and Admission Officers (AACRAO). Reporting five times within a traditional semester creates an approximate 30-day cycle from first submission to the next, keeping reporting to NSLDS well below the 60-day reporting minimum. Evidence of this will be shared in the College’s monthly Compliance Committee Meetings. To address the issues of reporting “less than half time” for students who were enrolled in zero hours, Good Samaritan College has contacted the Student Information System vendor, Ellucian, to identify a technological solution allowing the reporting of students with zero hours correctly. Until a technological solution can be found, the College Registrar will run a report to cross check against each enrollment transmission for National Student Clearinghouse identifying all students who drop to zero hours and report them as withdrawn to NSC. In turn, NSC will correctly report to NSLDS the status of withdrawn. Reporting is signed off and evidence of this will be shared in the College’s monthly Compliance Committee meetings. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science Expected Completion: February 2025

Categories

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

Other Findings in this Audit

  • 522285 2024-001
    Material Weakness Repeat
  • 522286 2024-001
    Material Weakness Repeat
  • 522287 2024-001
    Material Weakness Repeat
  • 522288 2024-001
    Material Weakness Repeat
  • 522289 2024-001
    Material Weakness Repeat
  • 522290 2024-001
    Material Weakness Repeat
  • 522291 2024-001
    Material Weakness Repeat
  • 522292 2024-002
    Significant Deficiency
  • 522293 2024-003
    Significant Deficiency Repeat
  • 522294 2024-004
    Material Weakness
  • 522296 2024-005
    Significant Deficiency Repeat
  • 522297 2024-006
    Significant Deficiency
  • 1098727 2024-001
    Material Weakness Repeat
  • 1098728 2024-001
    Material Weakness Repeat
  • 1098729 2024-001
    Material Weakness Repeat
  • 1098730 2024-001
    Material Weakness Repeat
  • 1098731 2024-001
    Material Weakness Repeat
  • 1098732 2024-001
    Material Weakness Repeat
  • 1098733 2024-001
    Material Weakness Repeat
  • 1098734 2024-002
    Significant Deficiency
  • 1098735 2024-003
    Significant Deficiency Repeat
  • 1098736 2024-004
    Material Weakness
  • 1098737 2024-005
    Significant Deficiency Repeat
  • 1098738 2024-005
    Significant Deficiency Repeat
  • 1098739 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $259.08M
93.600 Head Start $6.23M
84.268 Federal Direct Student Loans $4.18M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $3.67M
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.74M
84.063 Federal Pell Grant Program $1.76M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $1.74M
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $1.26M
14.241 Housing Opportunities for Persons with Aids $1.26M
93.556 Marylee Allen Promoting Safe and Stable Families Program $1.15M
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $1.13M
93.RD Federal Contract – Unmodified and Post Translationally Modified Cd4+ $1.09M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $894,897
93.U01 Aids Medical Waiver $872,171
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $830,790
93.914 Hiv Emergency Relief Project Grants $731,388
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $657,662
12.420 Military Medical Research and Development $649,658
16.320 Services for Trafficking Victims $622,471
93.493 Congressional Directives $590,000
93.778 Medical Assistance Program $476,394
10.568 Emergency Food Assistance Program (administrative Costs) $377,912
93.959 Block Grants for Prevention and Treatment of Substance Abuse $374,710
94.011 Americorps Seniors Foster Grandparent Program (fgp) 94.011 $348,354
93.211 Telehealth Programs $327,982
93.940 Hiv Prevention Activities Health Department Based $314,610
16.839 Stop School Violence $312,157
93.884 Primary Care Training and Enhancement $285,100
93.268 Immunization Cooperative Agreements $269,982
10.558 Child and Adult Care Food Program $253,574
93.276 Drug-Free Communities Support Program Grants $243,780
93.155 Rural Health Research Centers $213,209
93.310 Trans-Nih Research Support $202,906
10.855 Distance Learning and Telemedicine Loans and Grants $198,301
93.327 Demonstration Grants for Domestic Victims of Human Trafficking $196,733
93.324 State Health Insurance Assistance Program $180,022
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $169,295
93.597 Grants to States for Access and Visitation Programs $167,500
16.589 Rural Domestic Violence, Dating Violence, Sexual Assault, and Stalking Assistance Program $151,055
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $150,750
10.331 Gus Schumacher Nutrition Incentive Program $136,341
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $135,016
93.788 Opioid Str $126,344
84.425F Education Stabilization Fund $124,820
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $123,059
10.572 Wic Farmers' Market Nutrition Program (fmnp) $115,116
93.837 Cardiovascular Diseases Research $112,151
16.575 Crime Victim Assistance $111,095
93.575 Child Care and Development Block Grant $109,925
93.394 Cancer Detection and Diagnosis Research $108,154
16.842 Opioid Affected Youth Initiative $103,735
16.582 Crime Victim Assistance/discretionary Grants $98,900
93.988 Cooperative Agreements for Diabetes Control Programs $97,291
93.426 The National Cardiovascular Health Program $93,019
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $90,615
93.301 Small Rural Hospital Improvement Grant Program $87,888
93.053 Nutrition Services Incentive Program $87,695
93.241 State Rural Health Flexibility Program $81,790
93.350 National Center for Advancing Translational Sciences $78,508
93.838 Lung Diseases Research $78,388
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $72,269
93.686 Ending the Hiv Epidemic: A Plan for America � Ryan White Hiv/aids Program Parts A and B $63,100
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $60,007
93.052 National Family Caregiver Support, Title Iii, Part E $43,655
20.616 National Priority Safety Programs $40,596
93.262 Occupational Safety and Health Program $39,626
84.007 Federal Supplemental Educational Opportunity Grants $39,157
93.558 Temporary Assistance for Needy Families $36,892
93.RD Federal Contract - Tn-25: Rituximab Followed by Abatacept for Prevention Or Reversal of Type 1 Diabetes (t1d) $33,563
93.395 Cancer Treatment Research $33,347
93.435 The Innovative Cardiovascular Health Program $33,334
93.855 Allergy and Infectious Diseases Research $29,754
93.994 Maternal and Child Health Services Block Grant to the States $26,611
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $25,368
93.RD Federal Contract - Tn-28: Low Dose Atg in Prevention $23,818
93.069 Public Health Emergency Preparedness $23,199
93.870 Maternal, Infant and Early Childhood Homevisiting Grant Program $22,996
32.006 Covid-19 Telehealth Program $19,163
93.839 Blood Diseases and Resources Research $19,040
93.235 Title V State Sexual Risk Avoidance Education (title V State Srae) Program $16,686
93.889 National Bioterrorism Hospital Preparedness Program $16,620
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $16,503
93.667 Social Services Block Grant $16,279
93.RD Federal Contract – Tn01 - Pathway to Prevention $15,485
93.658 Foster Care Title IV-E $14,991
93.226 Research on Healthcare Costs, Quality and Outcomes $14,813
93.734 Empowering Older Adults and Adults with Disabilities Through Chronic Disease Self-Management Education Programs � Financed by Prevention and Public Health Funds (pphf) $14,442
93.866 Aging Research $13,513
93.121 Oral Diseases and Disorders Research $9,809
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $9,692
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $9,105
93.865 Child Health and Human Development Extramural Research $8,931
93.958 Block Grants for Community Mental Health Services $8,704
93.991 Preventive Health and Health Services Block Grant $8,021
94.021 Americorps Volunteer Generation Fund 94.021 $7,683
93.RD Federal Contract – Intergovernmental Personnel $6,477
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $5,842
93.RD Federal Contract - Tn-31: Trialnet Jakpot Study $4,594
93.113 Environmental Health $4,246
84.181 Special Education-Grants for Infants and Families $4,200
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $3,635
93.568 Low-Income Home Energy Assistance $2,493
93.RD Federal Contract - Tn-16: Long Term Investigative Follow-Up in Trialnet $1,779
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $1,507
97.067 Homeland Security Grant Program $702
10.766 Community Facilities Loans and Grants $598
93.393 Cancer Cause and Prevention Research $273
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $162
93.RD Federal Contract - Tn-35: Qualitative Research on Participant Engagement with Trialnet Studies $35
93.RD Federal Contract – Tn-18: Prevention of Abnormal Glucose Tolerance and Diabetes in Relatives At-Risk for T1d Mellitus $28
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $1