Finding 537459 (2024-002)

2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2022-23 and 2023-24 award years Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, 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. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal 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. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 2 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • East Stroudsburg University (P268K232133, P268K242133, P063P222133, and P063P232133): 3 of the 5 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 17 of the 40 students tested for award year 2023-24 • Kutztown University (P268K232135, P268K242135, P063P222135, and P063P232135): 2 of the 5 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 22 of the 40 students tested for award year 2023-24 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 12 students tested for award year 2023-24 • Indiana University (P268K232107, P268K242107, P063P222107, and P063P232107): 3 of the 40 students tested for the award year 2023-24. 3) Incorrect Program Enrollment Status Reported to NSLDS • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 4 of the 12 students tested for award year 2023-24 • Commonwealth University (P268K242129, P268K252129, P063P222129 and P063P232129): 2 of the 40 students tested for award year 2023-24 • Millersville University (P268K242138, P268K252138, P063P222138, P063P232138): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student’s program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student’s program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 East Stroudsburg - Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 Commonwealth University (Lock Haven University) – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.