Finding 576787 (2023-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-10-18
Audit: 719
Organization: Southern Virginia University (VA)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University failed to report student enrollment statuses accurately and on time, impacting compliance with federal requirements.
  • Impacted Requirements: Enrollment reporting for Pell Grants and Direct Loans must be timely and accurate, including both Campus Level and Program Level data.
  • Recommended Follow-Up: Enhance internal controls and procedures for enrollment reporting to ensure compliance and timely updates to NSLDS.

Finding Text

Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 verify 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 which the financial aid administrator can access for the auditor. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time(F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. 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. Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 19 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days. For 1 of 40 campus level records tested, the University did not notify the Department of a change in the student’s enrollment. For 24 of 40 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: The majority of the certification delays were one day late. Corrective action has been taken. The financial aid office is working jointly with the registrar’s office to report enrollment information via the National Student Clearinghouse (NSC) which will facilitate more timely reporting of future enrollment status changes to NSLDS and reporting of all significant data elements to NSLDS. Reporting to NSC by the University Registrar’s Office has begun.

Categories

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

Other Findings in this Audit

  • 343 2023-001
    - Repeat
  • 344 2023-002
    Significant Deficiency Repeat
  • 345 2023-002
    Significant Deficiency Repeat
  • 346 2023-003
    -
  • 347 2023-003
    -
  • 348 2023-003
    -
  • 349 2023-003
    -
  • 576785 2023-001
    - Repeat
  • 576786 2023-002
    Significant Deficiency Repeat
  • 576788 2023-003
    -
  • 576789 2023-003
    -
  • 576790 2023-003
    -
  • 576791 2023-003
    -

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.60M
84.063 Federal Pell Grant Program $2.59M
84.007 Federal Supplemental Educational Opportunity Grants $69,716
84.033 Federal Work-Study Program $40,048
84.425 Education Stabilization Fund $23,482