Finding 540554 (2024-001)

- Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-29
Audit: 350312
Auditor: Galindez LLC

AI Summary

  • Core Issue: The University failed to report enrollment status changes for 17% of sampled students within the required 60-day period.
  • Impacted Requirements: Timely and accurate enrollment reporting is essential for compliance with federal regulations and affects student aid eligibility.
  • Recommended Follow-up: Ensure proper oversight and training for staff involved in enrollment reporting to meet federal deadlines and maintain accurate records.

Finding Text

Finding No. 2024-001 - Special Tests and Provisions – Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loans Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-four (24) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2024. As a result of our test, we noted that for four (4) out of twenty-four (24) students that received Student Financial Assistance funds, or 17% of the applicable sample, the University did not report to the NSLDS the students’ status change within the required 60 days’ period. Context Of the one hundred forty-three (143) instances of status changes, we selected twenty-four (24) that had received Student Financial Assistance funds and determined that for four (4) out of twenty-four (24) students that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Non-compliance was mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2023-001. Recommendation The University must ascertain that students’ documentation and other information necessary to comply with the federal funds’ enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on page 59

Corrective Action Plan

1. Implement new communication channels to align process to NSLDS and the USDoE.  Engage with NSLDS: Requested an access token for the data manager to monitor and reconcile data submitted.  Reach out to NSLDS to coordinate new reconciliation reports out of NSLDS database. 2. Training  Maintain sustained training and preparation for the staff. 3. Implement a weekly review process to double­check the entries for changes in enrollment reporting in NSLDS.  Implement a Document Changes and Actions Log: Keep detailed records of all changes made to procedures and actions taken to address the audit findings. This documentation can be useful for future reviews.  The Registrar will assure that all changes (LOA, withdrawals, re­ entries, and reclassifications, completions, graduations) are entered weekly and documented across all databases (NSLDS, Jenzabar student record, SRS, others as applicable).

Categories

Student Financial Aid Eligibility Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $20.05M
93.297 Teenage Pregnancy Prevention Program $645,086
84.063 Federal Pell Grant Program $343,368
93.732 Mental and Behavioral Health Education and Training Grants $328,290
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $188,002
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $146,522
93.060 Sexual Risk Avoidance Education $130,965
93.959 Block Grants for Prevention and Treatment of Substance Abuse $123,967
93.855 Allergy and Infectious Diseases Research $111,910
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $103,415
93.866 Aging Research $83,745
84.425 Education Stabilization Fund $71,543
93.396 Cancer Biology Research $49,367
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $41,608
93.279 Drug Use and Addiction Research Programs $31,140
84.033 Federal Work-Study Program $29,500
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $23,475
93.865 Child Health and Human Development Extramural Research $14,610
84.007 Federal Supplemental Educational Opportunity Grants $12,482
93.839 Blood Diseases and Resources Research $5,522
93.307 Minority Health and Health Disparities Research $3,619
93.859 Biomedical Research and Research Training $3,440