Finding 529177 (2024-002)

2024 002 Special Tests and Provisions (Enrollment Reporting) Student Financial Assistance Cluster: U.S. Department of Education Federal Pell Grant Program (ALN 84.063) Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P243920 (7/1/2023 – 6/30/2024), P268K253920 (7/1/2023 – 6/30/2024) Statistically Valid Sample: No, and it was not intended to be Prior Year Finding: Not a repeat finding. Finding Type: Significant Deficiency and Noncompliance Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and certify student enrollment statuses, program information and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting all Campus Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk: • OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting all Program Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk: • OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845 0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Additionally, in accordance with federal requirements, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context: The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. For five of forty students selected for testwork, the University did not report the student’s status as graduated within the Campus-Level Record or Program-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination. For one of forty students selected for testwork, the University did not report the student’s status as graduated within the Program-Level Record. The graduation status was properly reported in the Campus-Level Record. The University did properly report the student was withdrawn prior to determining if the student met the requirements for graduation and updating NSLDS to reflect that determination. Cause: The submission of certain student records was rejected by NSLDS in Summer 2024. Due to the volume of records rejected, the University needed time to resolve all errors and resubmit the rosters. During this process, the submission of the graduation information for the above individuals was missed. The management review control over the submission of the enrollment roster file did not operate at a precise enough level to identify the missing graduation information. Effect: Student status changes not reported in a timely manner could cause the student to not enter into repayment status on a timely basis. However, in this case, the student’s’ timely reported withdrawn status did cause the student to enter repayment status on a timely basis. Questioned Costs: None. Recommendation: We recommend the University enhance its current policies and procedures to ensure that when there are error codes generated from rejected NSLDS records that all student status changes are properly and timely reported to NSLDS when determined. Views of Responsible Officials: The University agrees with this finding. It is important to note that all six students were correctly reported with withdrawn status timely, and there was no delay of the students going into repayment status timely. The University has communicated extensively with the Clearinghouse about these six errors which are related to Error Code 75. The Clearinghouse has been working with NSLDS about the issues in these particular cases as they are not only related to the University. It is the University’s understanding that the errors were caused by a technical issue with the NSLDS system modernization and were out of the University’s ability to remedy. The University believes that the issue causing these errors is resolved and continues to monitor NSLDS’ error reports on the Student Status Confirmation Reports (SSCR) to ensure we are aware if they return. The University will continue to submit the SSCR responses to the Clearinghouse and ensure we report individual graduations or enrollment if there are error codes that cannot be resolved timely through the Clearinghouse process.