Finding 524779 (2024-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-27

AI Summary

  • Core Issue: The University has a significant weakness in its internal controls, leading to inaccurate and untimely reporting of student enrollment data to NSLDS.
  • Impacted Requirements: The University failed to comply with 34 CFR 682.610, which mandates accurate reporting of enrollment status every 60 days and timely responses to NSLDS.
  • Recommended Follow-Up: The University should revise its reporting procedures to ensure compliance with federal regulations and improve the accuracy and timeliness of enrollment data submissions.

Finding Text

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 out of the 60 students tested did not have enrollment data certified every 60 days. In 10 of the 60 students tested, the students’ status per the institution's records did not match what was reported to NSLDS. Furthermore, 14 out of the 60 students had an incorrect enrollment effective date. Lastly, 1 of the 60 students tested was not reported to NSLDS at all but should have been. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes – 2023-002 Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Background: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Records and Data Specialist o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Bethel Information Technology Staff Based on the previous audit, adjustments were made to standardize the submissions to the Clearinghouse. Extra efforts were made to ensure that needed corrections were done within the required time frame. We have started to simplify our degree conferral policy to improve the accuracy of the reporting of graduates. However, because of major changes in the Information Technology Department staffing, we were not able to research how the submission reports are compiled or the automatic process that is used to clean and prepare the data before it is added to the submission reports. We have reviewed the Clearinghouse training. We have also sought the advice from other institutions who report to the Clearinghouse. We originally thought that the frequency of our batches was the problem. However, it appears that the issues may be in the way the submission data are prepared and compiled into the submission reports. Multiple reports must be compiled and then combined to create the submission for both branches. Corrective Action: Our corrective action will involve several parts. • First, we will work ITS staff to determine which fields and tables the submissions are using to create the Clearinghouse reports. Currently, the submission batches are reporting on two branches where multiple terms (i.e. termcodes) are involved. The reports may need to some revision. • Second, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner • Third, we will monitor closely what the Clearinghouse records show for graduation and withdrawal dates for students in comparison to what is in our student information system to ensure they are in sync. Then we will double check that information to what is showing at NSLDS. Corrections will be made if needed. • Fourth, we will continue to adjust our conferral process to ensure that graduation information is reported in a timely way • Fifth, we will confer with the Financial Aid Office when dealing with complicated registration changes. This will ensure we are in sync in our interpretations of the situation. • Sixth, we will continue to take advantage of Clearinghouse, Banner, and any other related training opportunities. Name of Contact person Responsible for Corrective Action: Cheryl Fisk Planned completion date for the correction action plan: June 1, 2025. This will provide time to test corrective measures to ensure everything is submitting properly.

Categories

Student Financial Aid Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 524780 2024-002
    Material Weakness Repeat
  • 524781 2024-002
    Material Weakness Repeat
  • 524782 2024-002
    Material Weakness Repeat
  • 524783 2024-002
    Material Weakness Repeat
  • 524784 2024-002
    Material Weakness Repeat
  • 524785 2024-003
    Significant Deficiency
  • 1101221 2024-002
    Material Weakness Repeat
  • 1101222 2024-002
    Material Weakness Repeat
  • 1101223 2024-002
    Material Weakness Repeat
  • 1101224 2024-002
    Material Weakness Repeat
  • 1101225 2024-002
    Material Weakness Repeat
  • 1101226 2024-002
    Material Weakness Repeat
  • 1101227 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $20.09M
84.063 Federal Pell Grant Program $2.52M
84.007 Federal Supplemental Educational Opportunity Grants $429,582
84.033 Federal Work-Study Program $378,603
84.038 Federal Perkins Loans $162,726
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $115,927
47.049 Mathematical and Physical Sciences $27,825