Finding 524677 (2024-002)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2024

Accepted

2025-02-27

Audit: 344109

Organization: La Salle University (PA)

Auditor: Cliftonlarsonallen LLP

AI Summary

Core Issue: The University failed to report student enrollment data accurately and on time to the NSLDS, with discrepancies noted in effective dates and timely updates.
Impacted Requirements: Regulations require enrollment status changes to be reported within 30 or 60 days, and corrections must be made within 10 days for any errors.
Recommended Follow-Up: The University should review and improve its policies and procedures for reporting student status changes to ensure compliance with federal regulations.

Finding Text

2024 – 002 – National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Award Period: 7/1/23-6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following out of our sample of 40 students tested: • 3 students had effective dates at the campus and program level that did not agree between the University’s records and the NSLDS • 8 students were not reported to the campus level record in NSLDS in a timely manner. At a minimum, schools are required to certify enrollment every 60 days. • 1 student was never reported to NSLDS. Cause: The University’s process in place for timely reporting and updating effective dates within the Banner system were not functioning properly. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding : Like many US institutions, La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. In order to comply with established regulations, we set up an Enrollment Reporting Submission Schedule with the NSC. La Salle's schedule for 2025 is below: Term Begin Date Term End Date Transmission Type : Schedule Transmission Date Received Date Transmission Status 1/ 13/ 2025 5/ 9/ 2025 F rst of Term 1/ 31/ 2025 1/ 31 /2 25 Edtts Comp eted 1/13/ 2025 5/9/2025 Subsequent of - erm 2/ 17/ 2025 Not Yet Rece ed 1/ 13/ 2025 5/ 9/ 2025 Subsequent of Term 3/ 17/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5/ 9/ 2 25 Subsequent of-erm t./ 15/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5_/9/ 2025 Subsequent of -e,m 5/ 20/ 2025 Not Yet Rece v ed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er F,r;.: 6/ 3/ 2025 Not Yet Rece ved 5/ 19/ 2025 8/ 22/2025 Summer Subsequent 7/ 9/ 2025 Not Yet Recewed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er Subsequent 8/ 13/ 2025 Not Yet Recev ed 8/ 25/ 2025 12/ 13/2025 F rst of Terr, 9/ 23/ 2025 Not Yet Rece'ved 8/ 25/ 2025 12/13/ 2025 Subsequent of Term 10/ 28/ 2025 Not Yet ReceiVed 8/ 25 / 2025 12/ 13/ 2::>25 Subsequent of-erm 11/ 15/ 2025 Not Yet Rece·ved 8/ 25/ 2025 12/ 13/ 2025 Subsequent of-erM 12/16/ 2025 Not vet Receved Adherence to this reporting schedule would ensure timely reporting, as the NSC subsequently transmits data monthly to NSLDS, throughout the academic year, well within the requirement to report student enrollment status at least every 60 days. Our Associate Registrar for Academic Information Systems is specifically charged with maintaining, executing, and adhering to this schedule, as part of the routine duties assigned to that position in our office. Regarding accuracy, data structures are defined in our BANNER database to classify a given student's enrollment status in a given semester as full, three-quarter, half, or less-than-half time, and withdrawn. Those structures are long-established by student level (graduate, undergrad, doctoral), and do not change from semester to semester. BANNER processes extract the registration data and its timing, in light of those definitions and the data is formatted for transmission to the NSC as prescribed. Sound data entry practices have been established to make certain dates associated with those statuses, and the transition of a student within them, are accurately recorded. Consequently, we rely on the BANNER NSC extract, and the NSC's reporting relationship with NSLDS to accurately transmit that data accordingly. The NSC does work with us to rectify or resolve any seemingly inconsistent or incorrect data, based on prior transmissions and current regulations, prior to committing the given enrollment extract to the NSC database for our institution. They help us stay in compliance and consistent on both the campus-level and program-level basis upon which we're required to report. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Fall 2024

Other Findings in this Audit

524672 2024-001

Significant Deficiency Repeat
524673 2024-001

Significant Deficiency Repeat
524674 2024-001

Significant Deficiency Repeat
524675 2024-001

Significant Deficiency Repeat
524676 2024-001

Significant Deficiency Repeat
524678 2024-003

Significant Deficiency Repeat
524679 2024-004

Significant Deficiency
524680 2024-004

Significant Deficiency
524681 2024-004

Significant Deficiency
524682 2024-004

Significant Deficiency
1101114 2024-001

Significant Deficiency Repeat
1101115 2024-001

Significant Deficiency Repeat
1101116 2024-001

Significant Deficiency Repeat
1101117 2024-001

Significant Deficiency Repeat
1101118 2024-001

Significant Deficiency Repeat
1101119 2024-002

Significant Deficiency Repeat
1101120 2024-003

Significant Deficiency Repeat
1101121 2024-004

Significant Deficiency
1101122 2024-004

Significant Deficiency
1101123 2024-004

Significant Deficiency
1101124 2024-004

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
84.268	Federal Direct Student Loans	$24.60M
84.063	Federal Pell Grant Program	$5.00M
84.038	Federal Perkins Loan Program_federal Capital Contributions	$1.67M
84.007	Federal Supplemental Educational Opportunity Grants	$340,782
84.033	Federal Work-Study Program	$213,132
47.076	Stem Education (formerly Education and Human Resources)	$56,845
45.162	Promotion of the Humanities Teaching and Learning Resources and Curriculum Development	$27,830
93.124	Nurse Anesthetist Traineeship	$25,781