Finding 524713 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-27
Audit: 344144
Organization: Norwich University (VT)

AI Summary

  • Core Issue: The University failed to report student enrollment changes to NSLDS accurately and on time.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and 34 CFR 685.309 regarding timely and correct reporting of enrollment status.
  • Recommended Follow-Up: Review and improve reporting processes to ensure timely and accurate submissions to NSLDS.

Finding Text

Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Regulations require the status include an accurate effective date. 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. Context: During our testing of 40 students, we identified 2 students tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify the students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment of interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Corrective Action Plan

Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The errors noted in the finding resulted from a missing step in the reconciliation process. Until recently the Registrar’s office relied on an error report from NSC to help identify any issues that might be noted in the student files. The findings noted, reenforced that this process alone was not sufficient to capture all errors. To ensure that these types of errors do not reoccur, subsequently, the registrars office team has initiated an additional monthly reconciliation between the NSLDS and internal student management system. This reconciliation will show any status variance or date mismatches. Any variances noted will be updated in the NSC/NSLDS system. Name(s) of the contact person(s) responsible for corrective action: Sarah Harris, Director, Office of Financial Aid Planned completion date for corrective action plan: December 2024

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 524714 2024-001
    Significant Deficiency
  • 524715 2024-001
    Significant Deficiency
  • 524716 2024-001
    Significant Deficiency
  • 1101155 2024-001
    Significant Deficiency
  • 1101156 2024-001
    Significant Deficiency
  • 1101157 2024-001
    Significant Deficiency
  • 1101158 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $16.97M
84.063 Federal Pell Grant Program $3.52M
12.905 Cybersecurity Core Curriculum $2.15M
84.038 Federal Perkins Loan Program_federal Capital Contributions $2.09M
84.116 Fund for the Improvement of Postsecondary Education $1.56M
93.859 Biomedical Research and Research Training $1.06M
11.617 Congressionally-Identified Projects $856,692
84.007 Federal Supplemental Educational Opportunity Grants $635,374
94.493 Community Project Funding $473,136
84.033 Federal Work-Study Program $390,244
93.264 Nurse Faculty Loan Program (nflp) $151,127
12.910 Research and Technology Development $147,628
93.310 Trans-Nih Research Support $145,623
47.076 Stem Education (formerly Education and Human Resources) $138,968
20.701 University Transportation Centers Program $122,800
12.903 Gencyber Grants Program $115,985
97.005 State and Local Homeland Security National Training Program $71,020
15.810 National Cooperative Geologic Mapping $65,197
12.902 Information Security Grants $53,456
43.008 Office of Stem Engagement (ostem) $15,694
45.162 Promotion of the Humanities Teaching and Learning Resources and Curriculum Development $14,515
47.083 Integrative Activities $10,506
66.481 Geographic Programs – Lake Champlain Basin Program $2,431
43.001 Science $103