Finding 540602 (2024-001)

(3) Findings and Questioned Costs Relating to Federal Awards Finding No.: 2024-001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program ALN Numbers: 84.268, 84.063 Federal Award Year: July 1, 2023 – June 30, 2024 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment reported by institutions. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a 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 terms and conditions of the federal award. Condition Found In testing the Campus-Level enrollment reporting data elements as reported to NSLDS, key items to test are: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are: 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. Of the 40 students with enrollment changes that we selected for testwork, we identified three (3) students whose changes in enrollment status were not transmitted to NSLDS timely, as follows: • For two (2) students, the University was notified of each student’s enrollment status change from fulltime to graduated in May 2024. Accordingly, the students’ status changes should have been transmitted within sixty (60) days of degree conferral. However, submission was not timely, as the final submission of change of status ranged from sixty-nine (69) days to eighty-one (81) days after the required timeframe. • For one (1) student, the University was notified of the student’s enrollment status change from fulltime to withdrawn in May 2024. Accordingly, the student’s status change should have been transmitted within sixty (60) days of withdrawal date. However, submission was not timely, as the final submission of change of status was fifty-eight (58) days after the required submission date. Cause For the aforementioned three (3) students, the University’s internal control processes did not operate consistently to ensure that all enrollment information is transmitted to NSLDS timely. In each of these samples, additional manual intervention was required in order to successfully transmit the correct status due to either the original status submissions coming back as G Not Applied statuses, or students being enrolled in multiple concurrent programs which can create complexity with respect to status reporting. Due to staffing and resource constraints, the manual intervention required to resolve these items so that the correct status is reported to NSLDS did not occur in a timely manner. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the University review and enhance its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported to NSLDS in a timely and accurate manner. Views of Responsible Officials The University has identified a remediation plan in response to the finding, including the following: 1. Immediate Mitigations (within 90 Days): a. The Office of the Registrar and Office of Financial Aid and Scholarship programs will formalize a quarterly check-in meeting with multiple levels of stakeholders to ensure that our enrollment reporting process is complying and to address any new concerns that may arise. These check-in meetings have been scheduled and begin on March 26, 2025. 2. Long-Term Mitigations (within 12 months) a. The Office of the Registrar will work with ITS colleagues to implement a Graduates Only Enrollment file for multi-career students to increase the quantity of records that can be automatically processed. This work will be made productional by February 1, 2026 i. This will reduce our error rate and decrease the volume of records requiring manual review, allowing for more focused attention on the most complicated scenarios.