Finding 540599 (2024-001)

Finding 2024-001: Enrollment Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2023 through June 30, 2024 Federal Award Numbers P063P231924; P268K241924Criteria Per Section 34 CFR 685.309, a school shall update the student status confirmation report for changes in student status, report the date the enrollment status was effective and return the student status confirmation report to the Secretary within 60 days of receipt. Per Section 4.4.3 of the National Students Loan Data System (NSLDS) enrollment reporting guide, reporting of graduated status is critical to the protection of a student’s interest subsidy and initiation of repayment periods. Per 34 CFR 668.22(d), the number of days in the approved leave of absence (LOA) cannot exceed 180 days. Per Volume 5 Chapter 1 of the SFA Handbook, if an LOA does not meet the conditions for an approved LOA, the student is considered to have ceased attendance and to have withdrawn from the school, and the school is required to perform an R2T4 calculation. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 20 out of 40 students, the students were appropriately reported with a Graduated status but with an effective date of January 16, 2024, rather than May 10, 2024. For 1 out of 40 students, the student communicated an LOA that would last two semesters and therefore, does not meet the requirements for an LOA status. The student should have been reported with a withdrawn status effective January 16, 2024 but instead was reported as less than half-time status effective January 16, 2024 and then LOA status effective August 26, 2024 and then withdrawn status effective January 21, 2025. Cause and Effect The control that management sets a predetermined schedule to submit an enrollment report, on at least a monthly basis is to ensure timely reporting to the NSLDS, and reviews all reports for the accuracy of all data elements prior to submission was not operating at a level to identify all discrepancies. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year No. Recommendation We recommend the College enhance the precision of the control around the review of accuracy of the program level and campus level enrollment reporting submissions.Views of Responsible Officials The Financial Aid Office and the Registrar’s office agree that reporting to NDLDS for the year ended June 30, 2024 resulted in erroneous effective dates for graduated students and for one student on leave. A meeting has been set for both offices to meet and develop procedures to help ensure the reporting process is accurate. A plan is in place for review of the current year filings in early June 2025. A plan will be developed with dates for future years. This plan will include reporting procedures for all types of Davidson students who receive federal funds.